The Company has a regulatory compliance and criminal compliance and criminal and anti-bribery compliance model in accordance with the regulations ISO 37301, ISO 307001 and the Spanish criminal code that reflects its commitment to comply with current legislation. Within the same and in compliance with the Directive (UE) 2019/1937 a complaints channel has been put into operation as an instrument through which any interested party can reveal the possible commission of criminal acts within the Company or any conduct related to the breach of any legal, internal or policy rule of the same or within the framework of the aforementioned Directive. A the same time, this channel also serves to manage complaints, suggestions and opinions about the Company or any legal breach that can be detected.
The Company records that all those who, in good faith, use the channel will be protected against any type of retaliation, discrimination or penalti. In addition, it guarantees maximum confidentiality in this regards and is subject to current regulations on data protection in the treatment of personal information provided or obtained.
The Company has appointed an external criminal compliance organ that manages the complaints cannel and guarantees objectivity, transparency and impartiality in the processes of investigation and resolution of the complaints that are formulated.
To use the complaints channel, you must send an e-mail to the address miguelangel@tecnologiayderecho.es, or by mail to the address C/Catedrático Agustín Escardino Benllochj nº 9 (46980 Paterna). If the complaint, suggestion or opinión is directed against the compliance officer, it may be used by addressing the company’s management body.
Complaints will be evaluated within a máximum period of 3 months, after which a decisión will be made either to file the matter due to the absence of rational evidence of criminality and, where appropiate, transfer them to whomever is deemed or an opening of an investigation file in which evidence will be collected, always with the knowledge of the people involved and always under a strict regime of confidenciality regarding the identity of the complainant, being able to agree on measures for an effective investigation of the facts. After the end of the investigation, some conclusions will be given, and the complaint will be resolved within a maximum period of 1 month, in which there will be a proposal for a sanction in accordance with the collective agreement based on the seriousness of the incidents investigated and it will be recommended to the administrative body that they inform the competent authorities in the event that they have indications of criminal offense.