This document has been prepared with the purpose of establishing the Procedure for Managing Received Information, corresponding to the Internal Information System or Complaint Channel of this entity.
This Management Procedure respects and complies in all cases with the minimum requirements established by Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption.
This procedure applies to all notifications received through the Internal Information System or Complaint Channel of this entity.
3.1 - Of the administrative body/governing body of this entity/organization
3.2 - From the System Manager:
Any communication/complaint submitted through the channels established in this procedure will enjoy total and absolute confidentiality.
In any case, this entity will prioritize and respect the right to the presumption of innocence and the honor of any of the parties involved in a communication/complaint, ensuring that the rights of any person involved are not violated.
Throughout the investigation of a complaint, the affected person's right to be informed of the actions or omissions attributed to them will be guaranteed. However, the exercise of this right will be temporarily limited until the appropriate time to ensure the successful completion of the investigation.
Respect for the provisions on the protection of personal data will be guaranteed in accordance with the provisions of Title V of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption.
This entity will inform system users in a clear and accessible way about external channels of information to the competent authorities and, where appropriate, to the institutions, bodies or agencies of the European Union.
Specifically, the complainant is informed that:
The complainant, if an individual, has the following External Information Channels available, and may use them in the same way as this Internal Channel:
This entity has adopted as its Internal Information Channel, called the “Whistleblowing Channel”, an online complaint management system accessible from:
The entity's own website can be accessed via the following link:
https://canaldedenuncia.org/admin/login.php
Mobile application “Reporting Channel”, available for download via iOS and Android:
Android: https://play.google.com/store/apps/details?id=com.GrupoAtico34.canaldedenuncia
IOS: https://apps.apple.com/us/app/canal-de-denuncia/id1110646076?l=es&ls=1
5.1 - Complaint Submission Procedure
The Reporting Channel allows two ways for individuals who wish to submit reports, referred to hereafter as users, to do so:
Users can submit a report/complaint by accessing the link provided on the corporate website or through the mobile application "Complaint Channel".
Access will require users to use login credentials, specifically a "Username" and "Password". These login credentials can be provided to users in two ways:
Once the User accesses the link provided on the entity's website, they will be able to make an Anonymous Complaint by clicking on the "Anonymous Complaint" option.
Submitting an anonymous complaint will require completing the "Company Name (Company Name)" field correctly and following the instructions provided in the USER COMPLAINT CHANNEL USER MANUAL available to the entity.
5.2 - Receipt of the complaint, acknowledgments of status to the complainant and exchange of information between the complainant and the System Manager
The System Administrator will be able to manage and receive each complaint submitted by accessing it through the Complaints section within the online complaint management system, accessible via the link provided on the entity's website. To access this panel, the System Administrator will require a login using their Username and Password, provided by the entity.
Within your area of work for receiving and managing complaints, you will be able to distinguish between complaints that are in process and those that have already been reviewed and managed.
Within the "In Process" section, the System Manager will have at their disposal all complaints received to be managed, being able to differentiate whether they are complaints from Users identified by their name and surnames as well as those that are anonymous, the date of receipt or registration of each complaint, the number of days it has been open, as well as the status in which it is found.
The different states that may have the complaints in process are:
Once a complaint has been received by the System Manager, the required acknowledgment of receipt will be communicated to the complainant as soon as possible, and in any case within a maximum period of 7 calendar days from receipt, except in those cases where this may jeopardize the confidentiality of the communication.
Once the System Administrator communicates the acknowledgment of receipt to the complainant, the complainant will receive a notification informing them that it has been received via the email provided in their user profile within the system.
In the case of a non-anonymous complaint, the complainant can view the status of their complaint in the "Access Anonymous Complaint" section and through the tracking code provided to anonymous users when they submit their complaints.
The procedural stages in which a complaint can be found are:
Any changes to the status of complaints made by the System Administrator will be notified to the complainant who identified themselves when submitting the complaints via email. This applies provided the User has enabled email notifications of status updates.
As previously mentioned, the System Administrator will notify the complainant of the receipt of their complaint, as well as any other status updates they wish to make, through the "Notifications" section of their complaint management panel. The following complaint statuses may be communicated to the complainant:
The system will record the notifications made to the complainant, noting the date of sending, and will inform the System Manager whether it has been received and read by the complainant through their access to the online system.
Likewise, the System Administrator may modify the content of the message sent to the complainant when changing the processing status of each complaint.
5.3 - Handling of the Complaint
Once the System Manager has notified the complainant that the complaint is being processed, he will begin the investigation and development of the complaint.
The maximum period for responding to investigative actions may not exceed three months from the receipt of the communication or, if no acknowledgment of receipt was sent to the informant, three months from the expiry of the seven-day period after the communication was made, except in cases of special complexity that require an extension of the period, in which case, it may be extended up to a maximum of another three additional months.
Through the system you will have the possibility of working on the complaint, as well as issuing a report and sending it to the entity's governing bodies.
During the complaint process, communication with the complainant is possible, and if deemed necessary, additional information can be requested. This can be done through external channels or via the "Chat" button available on each complaint within the Complaint Channel itself.
In any case, the information contained in the complaint, or that which may be obtained during the investigation, will be immediately brought to the attention of the Public Prosecutor's Office when the facts may suggest a crime. If the facts affect the financial interests of the European Union, the matter will be referred to the European Public Prosecutor's Office.
5.4 - Completion of the complaint
Once the study and investigation of the complaint has been completed, the System Manager will communicate the acknowledgment of status to the complainant through the "Notify resolution of the complaint" option.
This notification of resolution of the complaint will in no case inform the complainant of the internal result of the investigation.
Once the complaint is completed, it will be listed in the Reviewed Complaints section within the Complaints section, and from then on it will be completely blocked and cannot be modified in any way.
5.4 – Receiving complaints through other channels
When the communication/complaint is sent through reporting channels other than those established or is directed to members of staff not responsible for its processing, who have been trained in this matter and warned of the classification of its breach as a very serious infringement, the recipient of the communication must immediately forward it to the System Manager.
Notwithstanding the foregoing, these types of communications will enjoy the same confidentiality as if it were a complaint submitted through the channels established by the entity.
1. INTRODUCTION
The Policy on general principles regarding the Internal Information System and whistleblower protection (hereinafter, Policy) aims to establish a foundation of principles intended to promote the correct use of the Internal Information System of this entity, as well as to guarantee a full protection of the whistleblower.
2.SCOPE
This policy applies generally and comprehensively to the present entity.
The principles of whistleblower protection and defense included in this policy will apply to whistleblowers in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption.
3. PRINCIPLES OF POLICY
This Policy aims to comply with the obligations contained in Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption.
Based on the legal content imposed in the aforementioned Law, this entity firmly commits to:
4. POLICY CONTROL AND COMPLIANCE
The entity's governing bodies will ensure the correct and appropriate compliance with the content of these Policies.
This document has been prepared with the purpose of providing all subjects included within the scope of the Internal Information System or Reporting Channel implemented in this entity, with all the necessary information on its use and application, all in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption.
The Internal Information System or Complaint Channel allows access to individuals who wish to file a complaint, hereinafter referred to as "users", through the entity's website and via the following link:
“Include Access Link”
The Reporting Channel allows users to submit complaints in two ways:
Through the entity's website, Users will be able to access the Reporting Channel by entering the following credentials: “Username” and “Password”.
The login credentials will be available to the User and will be sent to their email address once they have registered on the Reporting Channel access page. To do this, they must access the "New User Registration" option and complete each of the fields.
Once the User has their credentials, they must enter them and click on the “ENTER” option.
If the User has previously registered, and cannot remember their password, they can click on the "Remember login details" option, and follow the steps to recover their password.
Likewise, and before accessing, the user can change the language of the Reporting Channel by clicking on each of the different flags that are available.
Once inside the Reporting Channel, the User's first and last name will be displayed, as well as a horizontal menu located below it.
Clicking on each of the menu options will take you to them. The options shown in the menu are as follows:
3.A.1 - Profile
3.A.2 - New complaint
3.A.3 - List of Complaints
3.A.4 - Help Guide
3.A.1 - Profile:
The user will be able to modify the following data:
Once the data has been modified, whenever the new data is to be saved, the user must click on the "Modify data" button.
Likewise, the User is allowed the possibility of activating the option to (*) “Receive notifications” at any time.
(*) The “Receive notifications” option allows the user to decide at any time whether they wish to receive email notifications acknowledging the status of the complaint sent by the System Manager of the entity.
3.A.2 - New complaint:
This section allows the user to detail and explain the communication they wish to send to the entity through this channel.
The following fields will be displayed for completion:
You will need to click on the date format field dd/mm/yyyy to indicate the desired day, as well as click on the time format field --:-- to indicate the hour and minute.
If you wish to include a document with the communication, you must click on the blank field located below Attach document, and select the file location in your computer's file explorer.
To submit the complaint, the user must complete each of the fields provided, except for "Attach documentation" (optional), and click on the "Submit Complaint" button.
3.A.3 - Complaints List:
Within this option, the User will be shown a list of the communications made through the system.
This communications list allows you to list the communications made, displaying up to 10, 25, 50, or 100 on the same page. You can choose how to view them by clicking on the arrow below the "Show" option.
Similarly, the user will be able to search individually for a specific communication by entering the registration or sending date in the blank field located on the right side of the screen below the text “Search:”.
The communications list will show in each one the User's name and surname, their ID number, the Registration or sending date, the processing status in which the communication is found and the days that the complaint has been open from the sending until the resolution of the same.
From the Notifications section, the User will be able to view the different status acknowledgments of their complaints, which will be sent to them by the entity.
The status of the communications sent by the User to the entity will be updated as the information process progresses. However, the entity will notify the User of each status change via the email address provided in the "Profile" tab.
Through the “Messages” button, the User and the Entity Manager can initiate communication regarding each complaint made, as well as exchange documentation in this regard.
3.A.4 - Help Guide:
This section will allow the user to view a video guide on how to use the System.
Once the User accesses the link provided on the entity's website, they will be able to make an Anonymous Complaint by clicking on the "Anonymous Complaint" option.
This section allows the user to detail and explain the communication they wish to send to the entity through this channel.
The following fields will be displayed for completion:
You will need to click on the date format field dd/mm/yyyy to indicate the desired day, as well as click on the time format field --:-- to indicate the hour and minute.
If you wish to include a document with the communication, you must click on the blank field located below Attach document, and select the file location in your computer's file explorer.
To submit the complaint, the user must complete each of the fields provided, except for "Attach documentation" (optional), and click on the "Submit Complaint" button.
Once the User submits the report, a tracking code will be displayed on the screen. This code is unique and must be noted and kept safe by the anonymous complainant at the time of filing the report.
Given the confidentiality of this Reporting Channel, if the anonymous whistleblower loses this code, it cannot be provided by any other means, making it impossible to track the report.
3.B.1 – Follow-up on Anonymous Complaints:
Through the “Access Anonymous Complaint” button, the User will be able to access a Complaint tracking panel.
To access the tracking, the User must enter the complaint identification code that was provided to them when they submitted the complaint.
Once the User has accessed, they will be shown the information of their complaint with the Registration or sending date, the processing status in which the communication is found and the days that the complaint has been open from the sending until the resolution of the same.
From the Notifications section, the User will be able to view the different status acknowledgments of their complaints, which will be sent to them by the entity.
The statuses of the list of communications sent by the User to the entity will be modified as the information process progresses.
Through the “Messages” button, the User and the Entity Manager can initiate communication regarding each complaint made, as well as exchange documentation in this regard.
Communications to the Ethics Channel/Whistleblowing Channel can be made via email to buzoncodigoetico@scalperscompany.com. For cases where the report can be anonymous, the channel is available at the following link: Whistleblowing Channel Portal
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