Templates and records · SGE 21 · Clause 6.1.2
Ethics channel log under SGE 21 and Law 2/2023
Follow-up of every query, complaint or report received through the code of conduct channel, from receipt to closure.
In one sentence
The ethics channel log records every query, complaint or report received, how it was handled and how it was closed, because SGE 21 requires the code’s channel to guarantee anonymity, freedom from retaliation and follow-up of the matters logged (6.1.2), and for companies with 50 or more workers Spain’s Law 2/2023 adds the logbook, acknowledgement within seven days and a reply within three months.
- Where the standard requires it
- SGE 21 · Clause 6.1.2 Sections are cited using the numbering of the October 2024 version of SGE 21, the one Foretica publishes on its website. The Academy groups its nine management areas into six blocks.
- Type of information
- Mandatory record Follow-up of logged matters (6.1.2) and the Law 2/2023 logbook
- Who fills it in
- The person in charge of the internal reporting system With restricted access; the committee receives only aggregated information
- When
- For every report received Within the acknowledgement and reply deadlines of Law 2/2023
- How long it is kept
- Ten years at most Logbook limit (art. 26.2 of Law 2/2023); deletion after three months if no investigation (art. 32.4)
What the standard requires
What SGE 21 demands and what it leaves to your judgement
SGE 21 requires the code of conduct to set up a channel for questions, complaints, claims, reports or suggestions on ethical management and sustainability, with mechanisms guaranteeing anonymity, freedom from retaliation and follow-up of whatever is logged. The anti-corruption policy also requires anonymous reporting mechanisms (6.1.9).
In Spain, Law 2/2023 requires private entities with 50 or more workers to have an internal reporting system that accepts anonymous reports, to acknowledge receipt within seven calendar days and to reply within three months at most, extendable by a further three in complex cases.
The same law limits retention: logbook data may not be kept for more than ten years, and if no investigation has begun within three months the data must be deleted, except to leave evidence that the system works.
Structure
Fields the template should include
- Number, date and entry channel
- Type: query, complaint, suggestion or report
- Anonymous or identified report
- Subject and section of the code concerned
- Date of acknowledgement of receipt
- Investigation: person in charge and steps taken
- Outcome, measures and reply date
- Scheduled data deletion date
Example
Example: two reports from the year (invented data)
Company, people and figures are fictitious: the example only shows what a properly completed record looks like.
| Field | Content |
|---|---|
| CE-2026-011 | 4 May · web form · anonymous · report of degrading treatment by a site supervisor |
| Acknowledgement | 6 May, through the channel’s anonymous mailbox |
| Investigation | Interviews with six people at the site · system manager with external advice |
| Outcome | 22 June · facts established · sanction and change of supervisor · reply to the reporter via the mailbox |
| CE-2026-014 | 12 June · identified query on whether to accept an invitation from a client · answered in 2 days |
| Summary for the committee | 17 reports in the year · 9 queries, 6 reports, 2 suggestions · no personal data |
At the audit
Mistakes auditors commonly flag
- The channel is a generic email address anyone can read.
- It does not accept anonymous reports.
- Late acknowledgements, or replies that never arrive.
- Data kept indefinitely.
- The committee receives names instead of aggregated information.
In Kimobox
How this record is kept in Kimobox
- 1The whistleblowing channel is hosted on the portal, with restricted receipt and confidentiality.
- 2Each report has its own case file, traceable until closure.
- 3Ethics queries can be handled through the same channel.
Frequently asked questions
What people ask us before getting started
Can the SGE 21 channel and the Law 2/2023 channel be the same?
Yes, and that is the most practical option, provided it meets the requirements of both: those of the standard (anonymity, non-retaliation, follow-up) and those of the law (a designated person in charge, a procedure, deadlines and retention).
What if the company has fewer than 50 workers?
Law 2/2023 does not require it, except in the sectors the law itself names. SGE 21 does require the channel, regardless of size.
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Sources
Where each figure comes from
References to the official text in force. If a standard is revised, this page is updated and the review date says so.
- SGE 21. Sistema de Gestión Ética, Sostenible y Responsable (Ethical, Sustainable and Responsible Management System) Forética · October 2024 version
- Ley 2/2023, de 20 de febrero, reguladora de la protección de las personas que informen sobre infracciones normativas y de lucha contra la corrupción (Spanish whistleblower protection and anti-corruption law) BOE-A-2023-4513 · 21 February 2023