Whistleblowing Channel
SAN JOSÉ LÓPEZ S.A. WHISTLEBLOWING CHANNEL
According to the provisions of Law 2/2023, of February 20, regulating the protection of individuals who report regulatory violations and fight against corruption, all companies with more than 50 employees are obliged to have an internal reporting channel that allows
communications about those facts that may constitute a serious criminal or administrative offense, or alternatively, a violation of EU law.
On the other hand, in the regulations, it is stipulated the obligation to provide stakeholders with information on the use of any internal reporting channel, as well as the essential principles of the procedure.
To ensure compliance with the above, we provide the following:
1. General Policy of the SII. [ link]
2. Internal Information Channel User Manual [ link]
SAN JOSÉ LÓPEZ S.A. informs:
WHISTLEBLOWING CHANNEL. This whistleblowing channel ensures compliance with the provisions established in the aforementioned regulations, in accordance with Articles 7 and 9 therein.
ANONYMOUS COMMUNICATIONS AND PERSONAL DATA. Communications may be anonymous, and it is not mandatory to identify the informant. Responses will be provided through the same channel through which they were received. To facilitate this, it will be necessary for you to retain the tracking code assigned to you in the receipt message of the report.
Anonymity will only be lifted with the explicit consent of the informant or when it constitutes a necessary and proportionate obligation imposed by Union or national law in the context of an investigation conducted by national authorities or within the framework of judicial proceedings, particularly to safeguard the right to defense of the affected person.
Throughout the process, compliance with current data protection legislation will be ensured. (LOPD and GDPR)
USE OF THE WHISTLEBLOWING CHANNEL. When filing a report, you will notice that it is directed to an online tool external to the domain of SAN JOSÉ LOPEZ S.A. The message is transmitted to an external provider's tool to ensure complete objectivity and transparency in the management process of the report.
In any case, the external provider will comply with the instructions established by SAN JOSÉ LOPEZ S.A. and always in accordance with current data protection legislation, ensuring compliance with the obligations provided for in Article 28 of the GDPR
Therefore, this tool may be used by any employee of SAN JOSÉ LOPEZ S.A or any other third party who may become aware of unethical, fraudulent, or unlawful conduct within our Organization.
This whistleblowing channel is not the appropriate channel for issues related to your employment conditions or disciplinary matters. In such cases, you should follow the policies established within your organization.
ACCESS WHISTLEBLOWING CHANNEL FORM (Link)
The data controller is SAN JOSÉ LOPEZ S.A., which will process the information collected through the channel in compliance with a legal obligation established in Law 2/2023, of February 21, regulating the protection of individuals who report regulatory violations and fight against corruption. It will process the information for the purpose of
managing the reports received through the channel, ensuring the confidentiality of the informant's data by keeping them anonymous and not disclosing them to third parties unless their identification constitutes a necessary and proportionate obligation imposed by EU or national law in the context of an investigation conducted by national authorities or within the framework of judicial proceedings, in which case it must be communicated to the relevant authorities.
Your data will be kept for a maximum period of 3 months from the introduction of the data into the channel, but may remain blocked when necessary to evidence the functioning of the crime prevention model or when required by the competent authority to initiate the corresponding investigation of the facts.
For more information about the processing of your data or how to exercise your rights, you can refer to our Privacy Policy.