INTERNAL SYSTEM INFORMATION
In compliance with Law 2/2023, of February 20, regulating the protection of people that report on regulatory infringements and the fight against corruption, SERTIC, S.A.. has an Internal Information System (SII), being the company The person responsible for the processing of personal data in accordance with what It provides for current legislation in this area.
In order to strengthen the culture of information and integrity infrastructures the company and to promote the culture of communication as a mechanism of Prevention of actions or omissions that may be constitutive infringements under EU law, criminal offences or serious or very serious administrative procedures, as well as labor infractions in the field of safety and health at work, the company has a person in charge of Criminal Compliance (CPR) which is also Responsible for the System Internal Information (RSII). This person is currently the Person in charge of the Administration area (suppliers/accounting).
The aforementioned information can be made Arrive by any of the following means:
– Mail Electronic to the address: canaletic1@sertic.com
– Mail Ordinary to the address: C/ Ganiveters 13 – Polígono Industrial Els Ametllers park. 5, Solsona (25280), for the attention of the person CPR/RSII.
– By means of letter delivered to the person RCP/RSII.
The informant You can request within a maximum period of seven days a face-to-face visit with the person CPR/RSII.
Verbal information Collected in the aforementioned face-to-face visit, they must be documented in some In the following ways, with the prior consent of the informant:
(a)by means of a recording the conversation in a secure, durable and accessible format, or
(*) The informant will be warned that the communication will be recorded and will inform you of the processing of your data in accordance with the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
(b)through a Full and accurate transcript of the conversation conducted by staff responsible for processing it.
(*) Without prejudice to the rights that correspond to it in accordance with the regulations On data protection, the informant will be offered the opportunity to check, rectify and accept by your signature the Transcript of the conversation.
The SII of the company complies with the requirements of article 5.2 of the Law 2/2023:
a).- It allows the persons to whom the aforementioned Law applies (article 3) to communicate information, by various means, about the planned infringements in its article 2.
- b) .- It is managed in a way secure, ensuring that communications can be processed effectively within the company, as well as the confidentiality of the identity of the an informant and any third party mentioned in the communication and of the actions that are developed in the management and processing of the same, as well as data protection, preventing the access of non-personnel authorized.
c).- It has a Internal Information System Protocol, which establishes guarantees for the Protection of informants:
– Proof of receipt within seven calendar days following receipt of the information.
– Term maximum of three months to respond to the actions of the investigation, in the terms of section 9 of the Reference Act, supplementing and diligently guarding an Information Record Book.
– Possibility to maintain communication with the informant.
– Establishment of the right of the person concerned to be informed of the actions or omissions attributed to her and to be heard.
– Guarantee confidentiality when the communication is sent through complaint channels that are not those established or to personnel not responsible for their treatment, as well as the obligation that the person who receives it, immediately refers it to the person CPR/RSII.
– Respect to the presumption of innocence and honor of the persons affected.
– Respect to the provisions on Data Protection (Title VI Reference Law).
– Commitment of the submission of information to the Public Prosecutor’s Office immediately, when The facts could be indicatively constitutive of a crime.
TREATMENT OF PERSONAL DATA
SERTIC, S.A. Try The personal data included in the communications that are received and left protected by Law 2/2023 as the data controller, with the purpose to be able to manage them and initiate, where appropriate, the investigation procedure corresponding. The legal basis of the treatment will be the fulfillment of a legal obligation, derived from the Reference Law. If the communication contains: special data, the legal basis will be the essential public interest and Other provisions set forth in section 2 of Art. 9.2. of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of natural persons with regard to the processing of personal data.
It is also reported that such personal data may be processed and transferred by staff authorized to do so only, when necessary for the adoption of Corrective measures in the company in question or for the processing of disciplinary or criminal proceedings that, if where appropriate, proceed. Personal data will be kept for as long as Essential to decide on the origin of initiating an investigation about the reported facts. In any case, if this decision were not taken in a Within three months, the personal data contained in the communication will be shall delete, except for the purpose of maintaining evidence of the operation of the system.
They will also be deleted Those personal data not considered true, except that this is missing of veracity may constitute a criminal offense, in which case the Information for the time necessary during which the procedure is processed judicial.
Finally, it is stated that, At any time, the reporting person may request the person responsible for the treatment, access to your personal data, rectification or Deletion, or the limitation of its treatment, or to oppose it, as well as the right to the portability of the data, a letter accompanied by a photocopy of the your identity document in SERTIC, S.A., at the address Calle Ganiveters 13 – Polígono Industrial Els Ametllers parc. 5, Solsona (25280), or by sending an email to sertic@sertic.com. In case of Disagreement with the processing of your data, you may present a claim before the Spanish Data Protection Agency, body that holds supervisory authority in the matter, located at C/ Jorge Juan, 6 (28001) Madrid (www.aepd.es).
NON-RETALIATION
SERTIC, S.A. Will expressly undertakes not to carry out acts constituting retaliation, including threats or attempted retaliation against those presenting a communication in good faith in accordance with the provisions of Law 2/2023, and to be applied protection measures during the processing of a case, with respect to the people affected by possible communication.
EXEMPTION I MITIGATION OF THE PENALTY
It is reported for the appropriate purposes that, in accordance with the provisions of Law 2/2023, when The person who had participated in the commission of the administrative offence object of the information is the one that reports its existence through the presentation of the information (and provided that it had been presented prior to notification of the initiation of the proceedings of investigation or sanctioning), the competent body to resolve the proceedings, By means of a reasoned resolution, it may exempt said person from the Compliance with the administrative sanction that corresponds to it whenever they result accredited the extremes mentioned in section 40 of the Law of reference.
(*) The Internal Information Channel allows the presentation of communications Anonymous.(**) Although, whenever possible, the Internal Information Channel will be the Preferential means of communication, communications covered by Law 2/2023 may also be referred to where appropriate, when the object and gravity of the situation requires it and the informant deems it appropriate, to the Authority Independent Protection of the Informant or the authorities or bodies competent of the Autonomous Communities, within the scope of their respective powers, to the Public Prosecutor’s Office or the European Public Prosecutor’s Office, as appropriate.
