Transparency

CIRCE has the firm objective of promoting, establishing, developing and maintaining an appropriate ethical culture, expressly subject to the legislation and regulations in force at all times, and has therefore developed its own model of compliance and prevention of criminal risks. Among other actions, CIRCE has analyzed the risks inherent to its different activities in order to delimit and know the most sensitive ones and their risk typology.

Therefore, on December 13, 2022, the Board of Trustees of CIRCE approved the Criminal Compliance Program - CIRCE, as well as the implementation of a specific channel for complaints (compliance@fcirce.es) and a Compliance Committee. This program involves the implementation of a supervision and monitoring model, consisting of the following documents:

Compliance Manual - General Part: includes the design and structure of the (i) supervision, monitoring and verification model, (ii) control body, (iii) financial and material resources management system, (iv) disciplinary system, (v) complaints channel, (vi) training and (vii) general controls that CIRCE has in place to prevent the commission of crimes.

Compliance Manual - Special Part: identifies the criminal risks that may hypothetically occur in CIRCE due to the activities it performs, so that these risks are detailed in annexes along with the control framework capable of mitigating them.
Code of Ethics and Conduct.
Action Plan.
Compliance Policy.

In addition, CIRCE is firmly committed to an appropriate model of management of European funds, which allows preventing, detecting and correcting conflicts of interest, corruption and fraud in the use of such funds. For this reason, CIRCE also has an Anti-Fraud Measures Plan, which allows it to guarantee that, within its scope of action, the aforementioned funds will be used in accordance with the applicable regulations and, in particular, with regard to the prevention, detection and correction of fraud, corruption and conflicts of interest.

CIRCE also makes available to its staff and third parties a channel for consultation and alerts on situations of fraud, corruption and conflict of interest in relation to the management of public funds, both national and European: compliance@fcirce.es.

The purpose of this channel is to fight against corruption, fraud and conflict of interest, as well as breaches of our internal regulations, so please use it responsibly. Communications received will be treated as strictly confidential and your personal data will be treated in accordance with current data protection legislation. The information provided will only be used for legitimate purposes related to the investigation of the reported facts. Communications may be made anonymously and CIRCE guarantees that there will be no reprisals against persons who report in good faith.