Additional information Welcome to the Ethics Channel Naturhouse. Then fill in the following form indicating the facts reported.

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INFORMATION: Welcome to the Ethics Channel Naturhouse. Please select whether you want to ask a question about our Code of Ethics and Conduct or make a report:

Any use of the Ethics Channel will be in accordance with the information provided in the Naturhouse Code of Ethics and Conduct and, in all cases, is subject to the contents of our Rules and Regulations and Privacy Policy, which must first be read and accepted. We also advise you to read the FAQ section, which shows the answers to some of the most frequently asked questions.

Calle Claudio Coello,n° 91,4ª Planta 28006 (Madrid) España
Teléfono: +34 672 372 912 / +34 91 432 39 53

Ethics Channel Rules and Regulations

1- The Goal of the Ethics Channel
The Ethics Channel is a tool provided by "Naturhouse Health, S.A." (henceforth, "Naturhouse") for people subject to the company's Code of Ethics and Conduct so they may ask questions regarding the code or, if appropirate, file reports, in compliance with these Rules and Regulations.

2- Questions regarding the Code of Ethics and Conduct
All those subject to the Naturhouse Code of Ethics and Conduct may ask any questions they may have regarding its content and interpretation, using the Ethics Channel enquiry form.

3- Basic principles for whistleblower actions
Whistleblowers must submit information in good faith, truthfully and with the sencere belief that they are acting properly and only to the benefit of Naturhouse, the State and/or society in general.

4- Reportable incidents
You may use the Ethics Channel to complain about illegal acts being committed within Naturhouse or to its detriment, breaches of its Code of Ethics and Conduct (henceforth "Reportable incidents", in plural or "Reportable incident", in singular), the breach of any internal guidelines, as well as any accounting or financial irregularities that may compromise the true image of the company.

5- Reportable persons
The following persons may be reported through the Ethics Channel: administrators, executives, employees, advisers, sub-contractors, distributors, suppliers and franchisees of Naturhouse Health, S.A., along with any other liable individuals or entities that may commit a Reportable Incident.

6- Persons who can submit a report
All those subject to the Naturhouse S.A. Code of Ethics and Conduct or «Liable Person», as defined in Point 2 of the aforementioned Code of Ethics and Conduct, have the unavoidable obligation and the legal duty to submit information on any Reportable Incidents of which they are aware.

7- Ethics Channel Operating Bodies

- Ethics Channel External Manager
We will rely on the constant collaboration of the Ethics Channel Management Officer, an external, independent and autonomous individual, whose appointment and dismissal are freely actioned at any time by the Naturhouse Audit Commission. Naturhouse.
The Management Officer will have the following functions, mainly, (a) working with the Ethics Committee, collaborating in disseminating the Ethics Code, training and information on ethics within the company and setting measures for monitoring and preventing the committing of offences and crimes; and (b) managing the Ethics Channel, receiving the questions and internal reports made through the channel; instituting proceedings for submitted reports, maintaining the confidentiality of whistleblowers and adopting the decision regarding whether reports are admitted or not; informing the Internal Auditor, Ethics Committee and Chairman of the Audit Commission about the reports received.

- Internal Auditor
Naturhouse's Internal Auditor will be informed by the Management Officer of all reports, questions and communication received through the Ethics Channel or in relation with this channel; it will approve the proposals made by the Management Officer with regards to not admitting reports that clearly lack grounds or content; it will be informed of all communications by the Management Officer to the Ethics Committee and the Chairman of the Audit Commission; and will collaborate in implementing the technical, organisational, training and any other measures decided upon by the Audit Commission.
Should the Internal Auditor be involved in any of the reported incidents, it will not be informed of the report in order to maintain its confidentiality and to protect the whistleblower, and the accused will only be notified of the report through the proceedings, according to the timelines and conditions stated in section 8.7 of these Rules and Regulations.

- Ethics Committee
An Internal Ethics Committee has been set up at the company with sufficient independence to undertake as many actions as necessary to ensure Regulatory Compliance.
The main function of this body within the Ethics Channel is to establish processes for investigating the reports received regarding criminal incidents or breaches of the Code of Ethics and Conduct by Liable Persons, as well as answering any questions received.
The Ethics Committee is the body in charge of proposing to the Audit Commission the adoption of the protective and corrective measures and penalties corresponding to each case.
This body directly depends on and reports to the Audit Commission, and the latter is in charge of ensuring the independence and effectiveness of the compliance function; proposing the selection, appointment, re-election and removal of the members of the Ethics Committee; proposing the budget; receiving regular information regarding its activities; and verifying that the top management considers the conclusions and recommendations included in its reports.
Should a report be made against any member of the Ethics Committee, only the members not involved in the report will be notified, in order to maintain its confidentiality and to protect the whistleblower, and the person accused will only be notified of the report through the proceedings, according to the timeline and conditions stated in section 8.7 of these Rules and Regulations.

- Audit Commission
The Audit Commission s the company's internal body which adopts the final decisions regarding internal reports received through the Ethics Channel, adopting the corresponding corrective measures and penalties for each case.

8- Report processing procedure

8.1. Report
All internal reports must contain, at least, (i) the personal details of the whistleblower - name, surname and identity card number, passport number and nationality; and (ii) the reported incident, giving as many details of the alleged offence as possible. For reports submitted online, the whistleblower will also need to provide a contact email address.
Reports may only be made in Spanish or in English and in writing, whether by completing an online form for this purpose or by post, preferably recorded and signed for, and sent to the following address:

Rafael de Juanes Doswell
Naturhouse Ethics Channel Management Officer
C/ Fernández de la Hoz, 31
28.010 – Madrid

Reports may not be made over the phone or via email or via any other channel other than those established in these Rules and Regulations.

8.2. Preliminary evidence
All those who submit a report should have rational evidence to sustain it, which means that preliminary evidence to prove the incident, at least circumstantially, must be provided together with the report.
Any material evidence permitted by Law will be considered valid proof. Documentary evidence is preferable, although witness evidence is also admitted -including the whistleblower's own testimony-, as well as pictures and sound and video recordings.
In all cases, all evidence must have been obtained lawfully, in compliance with the law and constitutional rights and guarantees.

8.3. Admission for processing
Reports will only be admitted for processing if they comply with these Rules and Regulations.

8.4. Corrections
Should there be any correctable defects with regards to a report, the Management Officer will notify the whistleblower of the need to correct the defect(s) within ten (10) working days from the day after the communication. The whistleblower shall be warned that the file on his report may be closed if he does not correct the defect before the deadline.

8.5. Closure
If the report does not comply with section 10 of the Code of Ethics and Conduct, for any reason whatsoever, or in the case that the defects identified in the report not have been corrected, the file will be closed.

8.6. Opening a case file
When a report is admitted to processing, the Management Officer will call on the Internal Ethics Committee, which will proceed to open a case file in order to take as many actions as it may consider appropriate to duly clarify and establish the facts. The Chairman of the Audit Commission in charge of supervising the functioning of the system shall be informed of the report at the same time.
The period for processing the case file shall be no longer than three (3) months from the date of opening.

8.7. Decisions regarding internal reports
Decisions regarding internal reports will be adopted by the Audit Commission. It will agree on adopting any measures it deems appropriate and these may include some of the following:

1. To urge the application of the corresponding disciplinary regime in accordance with the applicable collective labour agreement and labour legislation.
2. To adopt the corresponding contractual measures when the incident affects the maintaining of or compliance with a civil or commercial relationship.
3. To adopt actions to indemnify any possible aggrieved parties for the damage caused.
4. To inform the corresponding judicial or administrative authorities of the incident.
5. To propose the adoption of technical, organisational, training or any other kind of measure in order to prevent similar incidents from taking place in the future.

8.8. Notifying the accused
The accused have the right to know that a report against them has been submitted and they must receive notification of the existance of a report, togehter with a summary of the incidents reported, as soon as possible and always within a maximum of one (1) month from the date of the report.
The notification sent to the accused will not include the whistleblower's details, in accordance with the provisions in Rule 9.
Notwithstanding the foregoing, if there is a risk that notification to the defendant may jeopardize the ability of Naturhouse to effectively investigate the complaint, such notification may be postponed by resolution of the Ethics Committee while such a risk exists. The justification of this exceptional faculty of the Ethics Committee is to preserve the evidence avoiding its manipulation or destruction by the person accused or by third parties.

9- Confidentiality
As long as a report is submitted in good faith and in accordance with these Rules and Regulations, its processing will be confidential, which means the claimant's identity will be maintained in secret and kept confidential.
Whistleblower's details may only be revealed, if appropriate, to the legal authority in charge of investigating the incident.
Notwithstanding the foregoing, if as a result of the investigation into a report, it becomes clear that said report was false or that the whistleblower has acted in bad faith or showing flagrant disregard for these Rules and Regulations, as well as any legal measures that Naturhouse may take in this regard, the whistleblower's details may be revealed to the accused so that he/she may, in turn, take the appropriate legal action.

10- Anonymous reports
Anonymous reports will not be admitted for processing.

11- Absence of reprisals
Any reprisals, threats or coercion against whistleblowers are categorically prohibited, even when these have been made in bad faith, without prejudice to any actions the relevant body may deem appropriate in this case.
In order to guarantee the above, all whistleblowers are entitled to seek protection rom possible reprisals they may be suffering and guidance from the Management Officer or any member of the Ethics Committee.

12- Acceptance of Rules and Regulations and Privacy Policy
Submitance of an internal report implies complete and unreserved acceptance of these Ethics Channel Rules and Regulations and the corresponding Privacy Policy.

Frequently Asked Questions (FAQs)

What is an Ethics Channel?
An ethics channel is the company's internal tool that may be used by anyone to notify us any alleged illegal acts within the company or to its detriment and any alleged infractions of the Naturhouse Code of Ethics and Conduct or any other internal regulations. The ethics channel is also a conduit for people subject to the Naturhouse Code of Ethics and Conduct to ask any questions they may have regarding its content and interpretation.

Is it possible to submit information anonymously?
No. Whistleblowers must identify themselves with their full name and identity card or passport number and their nationality before they submit any information.

What are the guarantees provided to whistleblowers?
First, the company guarantees that any information submitted will be handled in a confidential manner. Whistleblowers' identities will be kept secret and their personal details shall only be revealed, if necessary, to the competent public authority to investigate the incident. Secondly, the company guarantees whistleblowers that they shall not be subject to any reprisals due to the submission of information. On the contrary, information provided in good faith is always welcome when it reveals irregularities taking place at the company. Whistleblowers also have the right to seek protection and guidance from the Ethics Channel Management Officer and/or the Ethics Committee, as well as advice on how to defend themselves against possible reprisals. Thirdly, whistleblowers are guaranteed that the information they submit shall be handled professionally by a specialist law firm.

Can I submit a report without any proof?
We will only admit reports based on the existence of evidence that an illegal act and/or an act that goes against the Code of Ethics and Conduct has been committed. Therefore, reports must be supported by proof, preferably document-based. Witness evidence is admitted -including the whistleblower's own testimony-, as well as pictures and sound and video recordings. It is important to highlight that whistleblowers must obtain any proof they submitt by lawful means.

What happens if a report is false?
All reports must be true and made in good faith and must comply with the Ethics Channel Rules and regulations. All users are warned that submitting false reports may constitute a crime of libel and defamation, described in articles 205 ss. of the Spanish Penal Code. The company may take legal actions against anyone who submits false information or in bad faith. In the case of false reports, the company may also reveal the whsitleblower's details to the accused so that he may take appropriate legal action.

Will the person accused be notified the existance of a report?
Yes. The law requires for the accused to be made aware that a report against him has been submitted and, therefore, as soon as proper checking and verification of the information has been made, and never later than three (3) months after the report, the company shall inform the accused of its existence. Nevertheless, it is important to stress that whistleblowers' details shall never be disclosed to the accused, except in cases of false reports.

Is there a time limit to check and verify a report?
A report, if admitted for processing, will lead to the opening of a case file to provide clarification regarding the reported incident(s). According to the Rules and Regulations of the Ethics Channel, the time period for processing the case may be no longer than three (3) months from the moment the case file is opened.

What consequences may an internal report bring if there is enough evidence of the commision of an act contreary to the law or the Code of Ethics and Conduct?
Following the company's checks and verifications, if there is enough evidence of the that an illegal act or an act against the Code of Ethics and Conduct have taken place, within the company or to its detriment, first, the company will immediately adopt all the necessary measures to bring these acts to an end or avoid them taking place. Then, based on the severity of the incident, the company may also decide to take the corresponding legal action against the person or persons allegedly responsible for said act(s), by presenting a claim, a report or any other legal action to the Courts, the Public Prosecutor's Office or the Police.

Privacy Policy

“NATURHOUSE HEALTH S.A.” (hereinafter referred to as “Naturhouse”), with address in Madrid, Calle Claudio Coello 91, 4th Floor (28006 - Spain), with NIF A-01115286, informs the users of the Ethics Channel (hereinafter referred to as the “Users”) that the personal data obtained through the Ethics Channel will be treated with the purpose of attending any queries or complaints made internally with regards to the alleged commission of acts contrary to the Law within Naturhouse or to its detriment and the breaches of Naturhouse’s Code of Ethics.

Lawfullness of processing personal data is based on the legitimate interest of Naturhouse in ensuring ethical and regulatory compliance within the organization, as well as in the consent of the Users with respect to any data they may provide.

The personal data concerned shall consist on the data included in the form or communicated by mail, as well as the the User's equipment IP data.

Data will be kept in the Ethics Channell only during the time necessary to decide on the appropriateness of initiating an investigation into the reported facts.

In any case, three (3) months after the data has been registered, it shall be removed from the complaint system, unless the purpose of the conservation is to leave evidence of the functioning of the legal entity’s crime prevention program.

Once the period mentioned in the previous paragraph has elapsed, the data may continue to be processed by the Naturhouse organ to which the investigation of the reported facts corresponds in order to process the internal investigation measures that may be necessary and, where appropriate, apply the disciplinary, contractual or judicial measures.

Personal data may be communicated to the Police, to other relevant organs of the Public Administration and to the Courts of Justice and other judicial organs.

Naturhouse undertakes to respect the confidentiality of the data included in the ethical channel and to use them in accordance with its purpose, as well as to comply with its obligation to store them and adapt all measures to avoid alteration, loss, treatment or unauthorized access in accordance with the provisions of current regulations. In particular, in accordance with the provisions of sections 7 and 9 of the Operating Rules of the Ethics Channel, Naturhouse will maintain the confidentiality of the data of Users who file internal complaints, preventing access to them by the alleged offenders.

Notwithstanding the foregoing, in the event that a report turns out to be false, the Users are informed that their data may be communicated to the alleged offenders so that they may, if they deem it appropriate, initiate legal actions against false accusation.

Personal data subjects may exercise, with respect to themselves, the rights recognized in General Data Protection Regulation and, in particular, the rights of access, rectification, deletion, opposition, portability, and restriction of processing.

The rights referred to in the preceding paragraph may be exercised by each data subject by email addressed to or by ordinary postal mail addressed to:

C/ Fernández de la Hoz, 31
28.010 - Madrid

Users and all other data subjects are informed that LEXPIRIT, S.L.P. is an external legal consultant of Naturhouse that holds the status of responsible for the treatment of the aforementioned Ethics Channel and that is entrusted to attend, on behalf of Naturhouse, the requests for the exercise of their rights by any affected data subjects.

In order for the data subjects to exercise any of the indicated rights, it will be necessary for them to include:

  • a. Name and surname of the data subject, photocopy of his or her national identity document, or passport or other valid document to prove identity and, where appropriate, that of the person representing the data subject, as well as the document to prove such representation.
  • b. Petition in which the request is specified.
  • c. Address for the purposes of notifications, date and signature of the applicant.
  • d. Documents to prove the request, if applicable.

Naturhouse also has a Data Protection Officer, with whom interested parties can contact by email for any incident related to their data at the following address:

Finally, data subjects are informed that they have the right to present, if they consider it appropriate, a claim before the Spanish Agency for Data Protection (Agencia Española de Protección de Datos), which is based in Madrid (28.001), at calle Jorge Juan, no. 6

For a more complete and detailed information of their rights, it is recommended that the data subjects visit the website of the Spanish Agency for Data Protection or that they contact it through their citizen service, by calling 901.100.099.

Thank you for your report

Your report has been worded correctly and It will be processed according to the procedure established in the Standards of Operation of the Ethical Channel. N/Ref: Report No. %d