The Whistleblowing Channel at PROMEGA enables the detection and prevention of conduct contrary to the law, internal regulations, business ethics, and compliance protocols. Situations such as fraud, harassment, discrimination, deceiving clients, unfair treatment of competitors, or any behavior that negatively affects employees’ professional development are expressly rejected.

  1. Subjective Scope

The channel is available to any person or company with a direct or indirect relationship with PROMEGA: employees, directors, suppliers, collaborators, external advisors, and associated companies. All of them may report facts, irregularities, risks, actions, or omissions that may involve crimes, regulatory breaches, or conduct contrary to internal protocols.

  1. Objective Scope

Through the channel, the following may be reported:

  • Indications, suspicions, or evidence of regulatory breaches.
  • Crimes or unethical behavior.
  • Breaches of protocols, rules, and codes of conduct.
  • Risks or breaches regarding data protection.
  • Discriminatory conduct, workplace or sexual harassment, and any other action contrary to equality and professional ethics.
  1. Principles of the Whistleblowing Channel
  • Confidentiality and Data Protection: The management of the channel guarantees the confidentiality of the identity of the whistleblower and any person involved, in compliance with data protection regulations. The right of access of the reported party never includes the identity of the whistleblower.
  • Professional Secrecy: All individuals who become aware of reports are obliged to maintain professional secrecy regarding the identity of the whistleblower.
  • Prohibition of Retaliation: Whistleblowers acting in good faith are protected against any type of retaliation, discrimination, or penalty. However, if it is proven that the report is false and made in bad faith, disciplinary measures may be taken.
  1. Reporting Mechanisms

Reports may be submitted via:

  • Ethics channel: You can scan the following QR code to access the whistleblowing channel directly.

Communications must respect data protection regulations and the anonymity of the whistleblower.

  1. Handling of Reports

The management of the external whistleblowing channel is entrusted to Quality Consultores, which guarantees independence, confidentiality, and data protection. The channel is not exclusive; there are other valid channels for reporting breaches.
Procedure:

  • Receipt: An acknowledgment of receipt will be sent within five business days when possible.
  • Admission: The plausibility and grounds of the report are evaluated. Unfounded reports, those not constituting an infraction, or mere repetitions of previously investigated reports will not be admitted.
  • Investigation: If the report is admitted, an investigation is initiated, with a maximum duration of three months. The right to be heard is guaranteed for the reported party and affected persons, while maintaining the confidentiality of the whistleblower.
  • Resolution: A reasoned decision is issued, which may uphold or dismiss the report. If an infraction is found, disciplinary measures are applied, or the competent authority is notified. Otherwise, the report is archived.
  1. Information Security

PROMEGA guarantees the privacy and protection of all personal data and documentation provided, adopting the necessary technical and organizational measures to prevent loss, misuse, alteration, unauthorized access, or theft of data.

  1. Applicable Law and Jurisdiction

These conditions are governed by Spanish law. Any dispute will be resolved in the Courts and Tribunals of Vigo.