Whistleblowing Channel

Club de Golf Terramar has implemented a Crime Prevention Model (CPM) that complies with legal requirements regarding corporate criminal liability (Article 31 bis of the Spanish Penal Code). The aim of this model is to prevent the organization from being used to commit crimes while promoting sound corporate governance.
This model involves identifying criminal risks that could potentially materialize within the club and implementing the necessary controls to prevent and mitigate such risks.

The club’s Crime Prevention Model is comprised of the following elements:

1. Criminal risk analysis
2. Risk matrix and map
3. Supervisory and control body
4. Code of Ethics
5. Reporting and investigations
6. Controls to mitigate the risks identified in the risk map
7. Contractual clauses
8. Communication and training plan
9. Monitoring plan
10. Annual review and update

This body is responsible for ensuring the implementation, supervision, and proper functioning of the Crime Prevention Model (CPM). It is composed of two Compliance Officers: Anna Caballero and Roger Soriano.

The proper functioning and effectiveness of the Crime Prevention Model require the implementation of an Internal Information System. This system allows employees, members, suppliers, and clients to maintain direct and secure contact with the supervisory and control body, enabling them to submit confidential reports. This facilitates the detection and prevention of crimes and/or inappropriate behavior within, by, or in connection with the Club.
The operation of the Internal Information System is regulated by the Internal Information System Protocol.
Reports can be submitted by email to: sistemainternoinformacion@golfterramar.com, or by completing the following form, which also allows for anonymous submissions: