What is an internal information channel?

This is the means by which employees and other persons can confidentially report conduct that may be contrary to the company's internal regulations, to the provisions of current legislation, when it constitutes a serious or very serious administrative offence, as well as breaches of labour law in matters of health and safety, conduct suspected of a criminal offence, breaches of European Union law in relation to its financial interests or that have an impact on the internal market.

How does it work?

• There is a form to make a communication of those behaviors that could be contrary to the law and the regulations of the organization by directors, employees, suppliers or other agents related to the activity of the companies of the IVIRMA Group. The informant may request a meeting with the person responsible for the internal information channel to carry out said communication. In that case, the communication shall be confidential.
• If you wish, the communication can be anonymous. When completing the form, your email, telephone number or any other information that identifies you will not be reflected. If you wish to submit an anonymous communication, in order to maintain absolute confidentiality, with the submission of the same, you will be provided with a tracking code to be able to follow the status of your communication, as well as to be able to communicate with the person responsible for the system.
• All evidence, images, videos or documents that support or prove the facts communicated may be attached.
• All submissions received will be reviewed and investigated by the Channel manager, who will develop the corresponding investigation was carried out with the objective of clarifying the truth or falsehood of the communication.

• Channel manager will ensure for the protection of the rights of the investigated and their personal data.

• Once a communication has been received, the procedure for managing it will be as follows:
• Sending the acknowledgment of receipt of the communication to the informant within the term of seven (7) calendar days from the receipt thereof unless this may jeopardize the confidentiality of the communication.
• The term to carry out the investigation may not exceed three (3) months from count from the receipt of the communication or, in the event that it had not been sent acknowledgment of receipt to the informant, three (3) months from the expiration within seven (7) days after the communication is made, except in cases of special complexity that require an extension of the term, in which case, this may be extended up to a maximum of another three (3) months additional. 
• The possibility of maintaining communication with the informant is established and, if deemed necessary, additional information will be requested from you. 
• The affected person has the right to be informed of the actions or omissions attributed to it, and to be heard at any time. This communication, will take place at the time and in the manner deemed appropriate by the Channel Manager in order to guarantee the good end of the investigation. During the processing of the communication, the presumption of innocence and the right to honor of the affected person shall prevail. 
• At the end of the investigation, the person in charge of it will make a report that it will send to the Board of directors, to take the appropriate measures.
• When the facts may be indicatively constituting a crime, it shall be The information will be forwarded to the Public Prosecutor's Office. If the facts affect the financial interests of the European Union, referral will be made to the European Public Prosecutor’s Office.

Objectives of communications:

• Detect illegal or irregular conduct.
• Access to the internal information channel of all our employees and third parties.
• Guarantee confidentiality and anonymity.
• Adequately protect the whistleblower as a fundamental part of the organization's culture of compliance.
• Reception and treatment of queries or communications about irregularities or breaches of regulations, committed by employees or stakeholders.
  
• Protect sensitive information of the IVIRMA Group.
• Preserve reputation.
• Build trust with our stakeholders.
• Improve internal processes.

Guarantees of the Internal Communication Channel:

• Employees will be informed of the purpose and operation of the internal information channel.
• Submissions may be anonymous (at the informant's choice), it is not necessary to include the identity of the informant, nor the department from which the communication comes, nor any information that allows it to be identified.
• Strictly confidential, only the people who manage the channel will have access to the communication and only they will communicate with the informant.
• Absence of reprisals, discrimination and/or penalization for good reporters faith.
• The informant may, where appropriate, exercise his/her Rights of access, rectification, opposition, deletion (“right to be forgotten”), limitation of treatment, portability and not to be subject to individualized decisions.
• The Channel Manager is autonomous and independent for the management of communications. 
• Establishes mechanisms to avoid conflicts of interest in the management and investigation of communications received.

External Communication Channels

The informant may use external channels designated by the competent authorities, in accordance with the legislation applicable in each case, to report possible irregularities. These may include the institutions, bodies, offices or agencies of the European Union empowered for this purpose, or entities from outside the European Union.