Ethical Mailbox

This Code of Ethics is mandatory for all members of the Lucta Group, regardless of their role and geographic location. In view of the current regulatory environment, the Board of Directors of Lucta Spain has decided to draw up this Code of Ethics in order to maintain and uphold the highest ethical standards in the carrying out of the company’s business activity.

The complete document is intended to serve as a guide for the actions of all employees, regulating daily decision-making and the day-to-day activity of the Lucta Group.

The Lucta Ethics Mailbox and its function is regulated in the Resolution Protocol.

The Lucta Ethics Committee is in charge of managing the Ethics Mailbox and the communications received through the following:

Lucta is committed to compliance with the law and its ethical principles and values in all areas of its business and commercial activity, a commitment reflected briefly in the Code of Ethics that serves as a guide for the actions of all employees, directors, advisors, and third parties with whom the Lucta Group maintains business relations, regardless of their function and geographical location.

Within the framework of the Corporate Compliance system implemented by Lucta, one of the fundamental tools to ensure regulatory compliance is its Ethical Mailbox, through which any person may (i) bring to its attention any regulatory non-compliance of which they are aware or has reason to suspect, or (ii) communicate any doubts they may have regarding regulatory compliance. Such communication can be made either identified or anonymously and will always be treated confidentially.

Lucta’s Ethical Mailbox is composed of the following communication channels: 

  1. The e-mail address enabled for this purpose:
  2. By directly informing one of the members of the Ethics Committee, verbally or in writing. In this case, the Ethics Committee member must communicate the information received to the e-mail address provided.
  3. At the complainant’s request, a face-to-face meeting may be held with a member of the Ethics Committee to explain and detail the facts of the complaint.
  4. By telephone. For this purpose, the contact telephone number is +34 93 845 89 32.
  5. Through the physical mailboxes enabled for this purpose in Lucta’s facilities.

The corresponding form is enabled to carry out the communication.

The Ethics Committee of Lucta has been appointed as Responsible for the internal information system (Ethical Mailbox), a committee which, in turn, has delegated to one of its members, the Director of Human Resources of Lucta, the management of the same and the processing of research files.

To regulate the use of the Ethical Mailbox and the procedure for the investigation and resolution of communications, Lucta has approved and implemented the Protocol for the management, investigation, and resolution of communications received through the Ethical Mailbox and the Whistleblowing Policy.

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