Internal Reporting Channel
07.2 Internal Reporting System Policies
The Internal Reporting System of GRUPO FERMOR ASESORES S.L.U. serves as the channel for confidential and effective communication of any information regarding irregular acts committed by GRUPO FERMOR ASESORES S.L.U. or its personnel, which have come to light within the framework of an employment or professional relationship with our organization, in accordance with the provisions of Law 2/2023, of February 20.
The organization has established the Internal Reporting System through the following channels:
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In writing:
Via email:
denuncias@asesoresinternacional.comBy postal mail, addressed to the Head of the Internal Reporting System / Representative before SEPBLAC of GRUPO FERMOR ASESORES S.L.U., at:
C/ JERONI POU Nº24 3ºA, 07006, PALMA, BALEARES -
Verbally:
At the request of the whistleblower, information may also be submitted through an in-person meeting with the System Manager, within a maximum of seven days from the date of the request.
In addition to these channels, reports can also be submitted through the external reporting channels of the competent authorities.
Upon receipt of the report, the person responsible for the Internal Reporting System will acknowledge receipt to the whistleblower within a period of less than 7 days, in the case of non-anonymous reports. In any case, the whistleblower will be informed of the rights and obligations established by personal data protection regulations.
The System Manager will issue a reasoned report that either upholds or dismisses the report submitted, justifying the decision in either case. The report will be notified to the whistleblower and the person affected within a maximum period of 3 months from the end of the 7-day period following the submission of the report, unless the case is particularly complex and requires an extension of the deadline, which may be extended by up to an additional 3 months.
During the investigation of the report, communication and contact may be maintained with the whistleblower, and if deemed necessary, additional information may be requested from them.
The organization guarantees that the person affected by the report will be informed of it, as well as of the facts described in a summarized manner. Additionally, the affected individual will be informed of their right to submit written statements and about the processing of their personal data. However, this information may be provided during the hearing process if it is considered that earlier disclosure could facilitate the concealment, destruction, or alteration of evidence.
The person responsible for the Internal Reporting System / reporting channel guarantees confidentiality for all those who use the system or channel. Furthermore, confidentiality is also guaranteed when the communication is submitted through reporting channels other than the ones officially established or to personnel not authorized to handle such matters.
During the processing of the case, those affected by the report will have the right to the presumption of innocence, right of defense, and access to the case file, as well as the same level of protection as that granted to whistleblowers, with their identity being protected and confidentiality of the facts and data involved in the procedure ensured.
The processing of personal data derived from this procedure shall be governed by Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights, and Organic Law 7/2021 of May 26 on the protection of personal data processed for the purposes of preventing, detecting, investigating, and prosecuting criminal offenses and enforcing criminal penalties.
The person in charge of the Internal Reporting System / reporting channel will immediately refer the information to the Public Prosecutor’s Office when the facts may potentially constitute a criminal offense or to the European Public Prosecutor’s Office if the facts affect the financial interests of the European Union.
The organization guarantees protection against retaliation for anyone who brings to its attention any potentially unlawful conduct, reports a regulatory breach, collaborates in an investigation, or helps resolve a matter.
Persons who report or disclose violations referred to in Article 2 of Law 2/2023, of February 20, and actions or omissions that may constitute a criminal offense or a serious or very serious administrative offense, will be entitled to protective measures, provided the conditions outlined in Article 35 of the aforementioned law are met. These protective measures are described in Article 38 of Law 2/2023, of February 20.
Reports or information will be stored on the organization’s premises in accordance with its document archiving and retention policy.
The organization maintains a record of all reports received. Reports will be retained only for the period necessary and appropriate to comply with the requirements established by Law 2/2023, regulating the protection of persons who report regulatory violations and fight corruption, and in accordance with Article 24 and other applicable provisions of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.