What is an Internal Information Channel?
It is a means through which employees and other individuals can confidentially report behaviors that may contravene the company's internal policies and procedures or the law, as well as acts or omissions concerning health and safety, conduct suspected of being a criminal offense, or violations of European Union law affecting its financial interests or impacting the internal market.
How does it work?
There is a form provided for reporting behaviors described above by directors, employees, suppliers, or other parties associated with IVIRMA Group 's activities. The informant may request an in-person meeting with the responsible person for the internal information channel to make such a report. In such cases, the communication remains confidential.
If desired, the communication can be made anonymously. When completing the form, no email, telephone, or any identifying information will be included. For anonymous reports, a tracking code is provided upon submission to ensure absolute confidentiality and enable communication with the system's responsible person.
Any evidence such as documents, images, videos supporting the reported facts may be attached.
All communications received are studied and investigated by the Channel Manager, who conducts an inquiry to clarify the accuracy of the report.
The Channel Manager ensures the protection of the rights of the investigated person and their personal data.
Upon receipt of a communication, the management procedure is as follows:
- Acknowledgment of receipt of the communication is sent to the informant within seven (7) calendar days from its receipt, unless this could jeopardize the confidentiality of the communication.
- The investigation period may not exceed three (3) months from the receipt of the communication. In cases where acknowledgment of receipt was not sent to the informant, the investigation begins within three (3) months after the expiration of the seven (7) day period following the communication. In cases of special complexity requiring an extension, this period may be extended by up to an additional three (3) months.
There is provision for maintaining communication with the informant, and additional information may be requested if deemed necessary.
The affected person has the right to be informed of the actions or omissions attributed to them and to be heard at any time. This communication takes place at a time and in a manner deemed appropriate by the Channel Manager to ensure the proper conclusion of the investigation. Throughout the process, the presumption of innocence and the right to honor of the affected person prevail.
At the conclusion of the investigation, the responsible person prepares a report to be submitted to the Board of Directors for appropriate measures to be taken.
If the reported facts may indicate potential criminal offenses, 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 illicit or irregular conduct. Remediate any impacts to the extent possible.
- Provide access to the internal information channel for all our employees and third parties.
- Ensure confidentiality and anonymity.
- Adequately protect the informant as a fundamental part of the organization's compliance culture.
- Receive and address queries or reports of irregularities or breaches of internal policies and procedures, or the law, committed by employees or stakeholders.
- Protect sensitive information of IVIRMA Group.
- Preserve reputation.
- Build trust with our stakeholders.
- Improve internal processes.
Guarantees of the Internal Information Channel:
- Employees are informed of the purpose and operation of the internal information channel.
- Submissions may be anonymous at the choice of the informant; there is no need to include the informant's identity, department, or any information that could identify them.
- Strict confidentiality: Only those managing the channel have access to submissions and communicate with the informant.
- Absence of reprisals, discrimination, or penalties against good faith informants.
- The informant may, where applicable, exercise their rights of access, rectification, opposition, deletion ("right to be forgotten"), restriction of processing, portability, and to not be subject to automated decision-making.
- The Channel Manager operates autonomously and independently for the management of communications.
- Mechanisms are established to prevent conflicts of interest in the management and investigation of received communications.
External Communication Channels:
The informant may use external channels designated by competent authorities, in accordance with applicable legislation in each case, to report potential irregularities. These include EU institutions, bodies, offices, or agencies empowered for this purpose, or entities from outside the European Union.
