Whistleblower Protection Channel
Welcome to the Whistleblower Protection Channel, established at ASESORÍA ALFE following the entry into force of the
the Law 2/2023, of February 20th, regulating the protection of persons who report regulatory infringements and the fight against corruption.
.
This channel has a dual purpose.
1. Firstly, it allows, through a secure channel, the communication by those persons who, in a work or professional context, as defined in Article 3 of the Law, detect irregularities, illicit acts or offenses listed in Article 2 of the Law.
2. Secondly, it guarantees the protection of these individuals against possible reprisals.
This channel uses mechanisms designed to ensure the confidentiality of all information and provides a secure environment for communication with
ALFE CONSULTANCY
allowing anonymous interaction between the company and whistleblowers.
What behaviors can be reported?
The communications submitted through the whistleblower channel must deal with conducts, facts, actions or omissions that involve:
1. A possible irregularity or act contrary to the ethical principles and values or any other applicable internal regulations;
2. Possible actions or omissions that may constitute a serious or very serious criminal or administrative offense.
3. Possible acts or omissions that may constitute breaches of European Union law.
The Whistleblower Channel will not be used to handle labor-related queries or commercial or contractual claims, which must be resolved in accordance with the legally established channels.
The Whistleblower Channel should not be used as a suggestion box.
Nor is it the appropriate way to contact the Data Protection Delegate at
ALFE CONSULTING
.
Who is entitled to file a complaint?
The Whistleblower Channel is available to all the members of
ALFE CONSULTANCY
(directors, administrators and legal representatives, executives, employees or persons under the authority of
ALFE CONSULTING
), as well as to legitimate third parties (shareholders, contractors, subcontractors, suppliers, trainees, persons working in training processes, job applicants, former employees, etc.).
The
Law 2/2023 of February 20, 23, regulating the protection of persons who report regulatory violations and the fight against corruption
has as its main objective to provide adequate protection against possible reprisals that may be suffered by individuals who denounce actions or omissions regulated by the Law. In order to guarantee this protection, the following rights are granted to the informant:
1. P
rohibition of retaliation
In compliance with the principle of whistleblower protection, those who make good faith reports as set forth herein are protected against retaliation, discrimination or penalization because of their report, unless an internal investigation demonstrates that the report was made with knowledge of its falsity, reckless disregard for the truth, bad faith or abuse of rights.
2. D
ight to receive information
If the whistleblower so desires, regular communication will be established to keep him/her informed about the progress of the investigation and the actions taken as a result of his/her complaint.
3. D
ight to limited information:
During the complaint process, only data essential to the processing and investigation is collected, avoiding requesting or retaining unnecessary information. The information provided is only used for research purposes, especially if it involves sensitive data such as trade secrets. If data is shared with third parties for the investigation, the informant and respondent are notified, except when authorized by law without consent. Compliance with data protection laws, including the EU General Data Protection Regulation and the Organic Law on Data Protection and Digital Rights, is ensured. Irrelevant or accidentally collected data is deleted immediately.
4. D
ight to anonymity: A whistleblower who files a report through the Whistleblower Channel will have the option to remain anonymous with respect to his or her identity. The anonymity of the informant will be guaranteed throughout the process, and it will be optional for the informant to include data that allow his/her identification through the reporting form provided.
5. D
ight to confidentiality
: The identity of the informant will be kept strictly confidential and will not be disclosed without his or her explicit consent, except in situations necessary for investigations by competent authorities or judicial proceedings, in accordance with exceptions established in European Union or Spanish legislation. Only the competent personnel in charge of receiving and handling complaints will have access to the identity of the informant.
6. D
ight to the deletion of data:
After three months have elapsed since the data were entered, they will be deleted from the reporting system, unless there is a legitimate purpose for their retention, such as to provide evidence of the operation of the internal information system, or if legal proceedings or investigations by the competent authorities arise from such retention. In such cases, the data will be stored in accordance with the applicable legal provisions and the requirements of the ongoing investigation.
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