RESPONSIBLE CHANNEL
WHAT IS THE RESPONSIBLE CHANNEL?
Minvestgrup makes the Responsible Channel available as communication mechanisms so that any non-compliance can be reported in order to promote respect for the law and the rules of conduct included in its Code of Ethics. Minvestgrup guarantees the confidentiality of the communications received, which may also be made anonymously.
We recommend prior consultation of the Responsible Channel Management Policy where you will find all the information about the channel.
This channel is not for complaints and/or claims about the service received from Minvestgrup. For this, the following email is enabled: sac@minvestgrup.com
WHO CAN REPORT?
– Employees, managers and the Sole Administrator.
– Shareholders
– Scholarship holders,
– Temporary employment agency workers,
– Collaborators,
– Suppliers and people who work for or under their supervision,
– Clients or potential clients,
– Former employees,
– Candidates for a job,
– Third parties with whom any type of relationship or link may exist, and Any third party who has detected illegal conduct.
WHO CAN BE REPORTED TO?
A complaint may be made against all employees, directors, the Sole Administrator, or external collaborators of Minvestgrup subject to its authority who have committed any irregularity or conduct of those provided for in the objective scope detailed in the Responsible Channel Management Policy.
WHAT IS THE PROCESS TO CREATE A COMPLAINT?
To send a report, access the platform and start by clicking on the “Channel access” button located on the left side of the Minvestgrup Responsible Channel introduction page. https://canres.page.link/kG1E
1. Once you access the page, you will first be asked to read, understand and accept the following documents: Channel Use Manual, Communications Management Procedure and Privacy Policy.
2. Once you accept, you will automatically access the “Previous data” screen where the following data will be requested:
– Type of communication that you want to make (infringement, irregularity, suggestion, doubt, complaint)
– Indicate whether or not it is urgent
– Type of relationship that the informant maintains with the organization (employee, manager, agent, client, supplier, partner)
– Areas that are considered violated (optional)
– A password must also be entered, which must be repeated to continue.
3. Next, you must choose the form of communication: through written form or personal interview. Once you have selected the form of communication, you can choose between:
Anonymous communication. The person who performs it will not have to indicate any personal information. As notices cannot be sent to you (communication status changes, requests…), you will have to access your communication in the channel to check if they exist.
Semi-anonymous communication. The person who performs it will have to indicate their personal data, but these will not be communicated to the entity. You may receive notices in the email you provide and your data will not be revealed to the entity unless you have acted in bad faith.
Non-anonymous communication. The person making the communication will indicate their personal data to the entity and will receive notices in the email provided.
Once this has been chosen, the form must be completed by filling out the following fields:
– Indicate when it has occurred or if it continues to occur
– Description of the facts
– Who knows the facts
– Which people or departments are involved
– Password reminder for tracking
Remember that you must save your password and reference number to be able to track your communication.
*ATTENTION: Through the use of the responsible channel, the protection of the person who files the complaint is guaranteed. Therefore, we ask that, if you want your communication to be anonymous, do not provide us in the description of the facts or in the documentation provided any personal data through which you can be identified.
Likewise, we recommend not using a device that has been provided to you by the company itself to submit your report.
HOW DO I FOLLOW UP A COMPLAINT?
To know the status of the complaint, you must access the platform and in the upper margin of your screen you will find “Communication Monitoring”. You must fill in the Complaint Reference and Password field and then click on the “Send” button. .
Once you enter the code that was generated at the time of the presentation, you will access your specific case, being able to view its status, provide new documentation or chat with the responsible channel manager.
Those who wish to have the complete Policy may request it at the following email address compliance@grupolmg.es
CUSTOMER SERVICE
In accordance with the regulations on transparency and customer protection of financial services, Minvestgrup makes available to its customers a Customer Service Department whose task will be to address and resolve customer complaints and claims.
Minvestgrup puts at your disposal all the means to respond to all your needs. Our staff is best suited to receive and resolve any possible suggestions, complaints or claims that may arise. To make your complaints or claims you must contact:
• By email, through the address sac@minvestgrup.com
• By phone at the following phone number 919 293 621
The Customer Service has a period of two months, from receipt, to respond to a complaint or claim. Therefore, if the complexity of the matter raised requires this maximum period, after it has elapsed, we will send you a definitive response or progress report.
If within the indicated period, and once you have exhausted the different instances that Minvestgrup makes available to you, you have not received a response or it is not satisfactory, you may contact as the next instance:
• Complaints Service of the National Securities Market Commission (CNMV) Commissioner for Investor Defense
C/ Edison 4, 28006 Madrid
www.cnmv.es
• Claims Service of the Bank of Spain
C/ Alcalá 48, 28014 Madrid
www.bde.es
• Claims Service of the General Directorate of Insurance and Pension Funds
Paseo de la Castellana 44, 28046
www.dgsfp.mineco.es
For more information about the operation of the Customer Defense Service, you can consult our Customer Defense Regulations.
ACTIVITY PROGRAMME
The Activities Program contains a description of the activities carried out by MinvestGrup.
INTERNAL REGULATION OF CONDUCT
The Internal Regulations of Conduct include the rules of conduct applicable to the activity carried out by MinvestGrup.
ETHICAL CODE
The purpose of the MinvestGrup Code of Ethics is to preserve and set an example of ethical behavior in accordance with its values as a company that provides financial advisory services.
RESPONSIBLE CHANNEL MANAGEMENT POLICY
The objective of this policy is to establish the guarantees for the protection of informants, the general principles that regulate the operation of the Internal Information System and its Procedure.
