Internal Information System

The Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta) establishes a framework to safeguard individuals who disclose misconduct or wrongdoing in the workplace, whether in the private sector or within public administration.

Such disclosures can be made through an Internal Disclosure, External Disclosure, and Public Disclosure.

To comply with said Act, in terms of Internal Disclosure obligations, MAPFRE Middlesea Group* has in place a specific policy and procedure, namely the Internal Information System Policy and the Information Management Procedure, that provide routes through which individuals in scope can submit a Complaint of a whistleblowing nature.

Disclosures made by natural persons who have obtained information about breaches in the workplace or as part of their professional relationship with the MAPFRE Middlesea Group shall be processed according to the process outlined in the Information Management Procedure. Natural persons in scope of this Procedure include:

• Members of the Board of Directors,
• employees whether full time or part time, volunteers, interns, trainees, and managers, even if the information communicated has been obtained within the scope of a labour or statutory relationship that has already ended or has not yet begun (in the latter case, if the information on the Breaches has been obtained during the pre-contractual selection or negotiation process),
• self-employed persons, contractors, subcontractors and providers, and any person working for or under the supervision and direction of the same, and
• shareholders, participants, and persons belonging to the administrative, management, or supervisory body of such companies

This Procedure is not designed as a Customer Service tool, and therefore, Claims or Communications/Complaints of a Commercial or Contractual Nature are not to be submitted in terms of this Procedure and will likewise not be processed through it.

*”MAPFRE Middlesea Group” (MMSG): Shall include MAPFRE Middlesea plc and the following subsidiary companies: MAPFRE MSV Life plc, BEE Insurance Management Limited, EuroMed Risk Solutions Limited, Church Wharf Properties Limited, and Middlesea Assist Limited.

• Email:
  • MAPFRE MSV Life plc: whistleblower@msvlife.com
  • MAPFRE Middlesea plc, and the remaining subsidiaries: whistleblower@middlesea.com
• In person: Hand-delivered to the WBRO.

Complaints may be submitted in a written format, verbal format, or both. Use of the official Complaint Form is recommended.

Acknowledgement of receipt of the Complaint will be provided within 7 days. Upon receipt of a Complaint, the WBRO will analyse and evaluate the Complaint. In the case of absence of basis for rejecting a complaint, the Complaint is referred to the Internal Information System Committee tasked with proceeding with investigations as necessary and if relevant.

Feedback on the Complaint will be provided within 3 months from the acknowledgement of receipt. For cases involving events or circumstances in which special complexity arises, at the discretion of the Internal Information System Committee, the aforementioned period may be extended to a maximum of three (3) additional months.

If it is believed that the WBRO may be involved, or is associated with a person who is or may be involved in an alleged practice, the complaint can be submitted to the Chairman of the Board or the CEO/General Manager of the relevant entity, who will escalate it to the Internal Information System Committee, in the manner deemed appropriate in the circumstances.

Guarantee of Protection

The confidentiality of the identity of the Informants and Persons Affected by the Complaint, as well as the facts and data contained therein, will be safeguarded throughout the entire process.

Furthermore, if the Informant discloses their identity during the submission of the complaint, the disclosure will be treated as a Protected Disclosure, and subject to the safeguards as outlined in the Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta).

Anonymously made disclosures will not be considered as Protected Disclosures.

If the Informant believes that as a result of their complaint, they are being made subject to detrimental action by any person within MAPFRE Middlesea Group, they are to immediately inform the respective WBRO.

A public disclosure shall be considered a protected disclosure under the Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta) if it fulfils the criteria set out in Section 3 of the Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta).

A public disclosure shall be considered a protected disclosure under the Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta) if it fulfils the criteria set out in Section 4 of the Protection of the Whistleblower Act (Chapter 527 of the Laws of Malta).