Stratio whistleblower channel

Start

Step 1/5 Categorize concern

To facilitate the further handling of your submission, please help us to categorise it as best as possible.

In which category does your submission best fit?

Environmental Protection

Harassment of myself or others

Product safety

Protection of personal data and privacy

Security of networks and information systems

Unethical behaviour

Others

Do you suspect any of the following people?

CFO

CIO

Data Protection Officer

Delegate for Occupational Risk Prevention

Director de Servicios Legales

HR Director

Managing Director

Personnel director

Purchasing Manager

Responsible for Internal Audit and Compliance

I am not aware of any involvement of these persons

I have read the Terms of use and agree to them in accordance with the notice.

Information

Step 2/5 Personal information

If you prefer not to give your personal details, you can do so by indicating that you want the report to be anonymous.

What is your relationship with the company being reported?

Do you wish to report anonymously?

Yes

This channel requires the whistleblower's identification data are mandatory.

The selected category requires the identification data to be mandatory

First name

Last name

Following the email validation policy, you must validate this email before filing the report.

Contact telephone number

This channel is confidential. Your personal data will not be shared. If someone from the organisation needs to know your data, they will request it through the channel and they will only be able to see it if you authorise it.

Details

Step 3/5 Detailed information

Describe in as much detail as possible the event you wish to report, giving as much information and attaching evidence, if available.

Indicate which person or persons are the subject of the report

First and last name

Position

Are there any witnesses? Please indicate their names.

First and last name

Position

Tell us what you want to report in detail

Would you like to attach any additional documents?

Image (png, jpg, gif), Audio (wav, mp3), Video (ogg, mp4, mov, avi, wmv, mpg, mpeg) or PDF document up to 20Mb. Attention! If you report anonymously, make sure that the attachments do not include information in the content or metadata that could identify you.

Confirm

Step 4/5 Confirmation

As the last step of the process, you must indicate a secret code that only you will know. This password, together with the identification code that we will give you at the end of the process, will be the only way to follow the progress of your submission

Password

Password confirmation

Email address validation

According to the validation policy of this channel, we must validate the indicated email address. To do so, we will send you an email with a validation email with a code that you must indicate in the following field.

Verification code check received

Finish

Step 5/5 Finalize

You have now entered all the information necessary to start the report management process.

The information is ready to initiate the process of determining accountability. The persons or facts reported will be investigated and the resulting actions will be taken.

The whistleblower undertakes that the information provided in this submission is true. Otherwise, the company reserves the right to take legal action against the whistleblower.

This is the last form in the process. When you click on Send, the investigation will begin and the resolution of your claim will be shown on the platform within a maximum period of 3 months.

I have read the Data Protection and Consent Notice and agree to the processing of my personal data in accordance with the provisions of this notice.

Terms of Use

In compliance with the Law on Services of the Information Society and Electronic Commerce, as well as in compliance with current regulations on data protection, it is reported that the owner of the website ithikios.com and canaldenunciasanonimas.com and all its subdomains ( hereinafter, "the Web") is DIGITAL PRODUCTS DEVELOPMENT SL (hereinafter, ithikios), registered in the Mercantile Registry of Barcelona, with CIF B02767010, and with registered office at c / Mont Blanc 17, Sant Cugat del Valles, Spain.

ithikios is the owner of all rights to the Website. The simple access, navigation and use of the Website attributes the condition of user of the same (hereinafter, the "User") and implies the acceptance of this clause of terms and conditions. The information available through this website is not subject to contract and may be modified without prior notice.

ithikios will not be held responsible for problems arising from the consultation or use of this Website. To this end, access is obliged to comply with this, having to act in accordance with current Law, good faith and public order and, refraining from using the Website in a way that could prevent or impair its proper functioning.

This service can only be used to send complaints or inquiries to companies that have contracted the service with ithikios, guaranteeing confidentiality and anonymity (if the user so chooses), regarding the personal data of the complainant.

Conditions for the user

As a user, you are obliged to make correct and lawful use of the platform.
You will use the platform for the purposes it has been designed for, and in no case will you use it for purposes contrary to the law.
The ithikios channel / canaldenunciasanonimas is not an emergency service. In case of emergency contact local authorities.
You must fill in all the information defined as mandatory in order to be able to send it.
This service is not designed to present information that can be considered secret or strictly confidential.
Reflect and review the information you send to ensure that if you do not want it, you do not reveal your identity.
You will be able to choose between sending the communication indicating your contact details or without indicating them. In both cases, the platform will provide you with a unique identification number and a password. It is important that you write them down in a safe place, only with them will you be able to check the status of the communication. If you lose them, you will not be able to access it again. For security reasons, ithikios will not be able to provide access to lost codes.
If the organization proves that there has been bad faith when making the report, it reserves the right to take legal action if the complainant has been identified.
You will be able to download a certificate issued by ithikios in which you will have all the information that has been sent to the company, as well as the result once the investigation is completed.
The query system has traces to help users identify improper access to their query.
The Complainant expressly understands and agrees that ithikios will not be responsible for any direct or indirect, anticipated or unforeseen damage, interest or loss, including, among others, moral damage resulting from the use or inability to use this service.
The Complainant is responsible for the veracity of the information communicated, assuming the consequences of having acted in bad faith or sent false information or documentation.
You will be liable for any loss or damage of any kind that ithikios may suffer, directly or indirectly, as a result of improper use of the product, a breach of the terms and conditions of use or a breach of the law in force on your part.

Data protection and consent to Stratio

TABLE OF CONTENTS

DATA CONTROLLER
MOTIVATION
SECURITY MEASURES
PERSONAL DATA PROCESSING
PURPOSES OF DATA PROCESSING
LEGITIMACY FOR DATA PROCESSING
RECIPIENTS OF THE INFORMATION
TIME LIMITS FOR DATA STORAGE
USER'S RIGHTS
ACCURATE AND TRUTHFUL INFORMATION

1. PARTY RESPONSIBLE FOR PROCESSING

This Whistleblower Channel is the responsibility of STRATIO BIG DATA, INC. Sucursal en España, with Tax Identification Number W4007784D, company address at Vía de las Dos Castillas 33, 28224 Pozuelo de Alarcón, Madrid, registered in the Commercial Registry of Madrid in book 33,891, folio 22, section 8, page M-609883, 1st entry (hereinafter, STRATIO).

We hereby inform you that STRATIO has appointed a Data Protection Officer who can be contacted at the following e-mail address [email protected].

2. MOTIVATION

STRATIO makes this Whistleblower Channel available to its stakeholders in compliance with the recent Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption (hereinafter, "Whistleblower Protection Law").

In addition, STRATIO fully complies with the current regulations on personal data protection; specifically, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of physical persons with regard to the processing of personal data and on the free movement of such data (hereinafter, "GDPR") and Organic Law 3/2018, of 5 December, on data protection and guarantee of digital rights (hereinafter, "LOPD").

3. SECURITY MEASURES

In compliance with the aforementioned regulations in force, STRATIO has incorporated the appropriate technical and organizational measures to guarantee the protection of the rights and freedoms of those affected by the processing of their personal data, including the corresponding data security measures, reinforced, among other aspects, with respect to the necessary confidentiality and, singularly, the disclosure of the informant's identity, data protection and the secrecy of communications, in order to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by the informant.

The submission and subsequent processing of anonymous communications shall be allowed. In the event that the communication received is not anonymous, the identity of the informant shall in any case be protected and the necessary measures shall be taken to guarantee the confidentiality of the information that is the subject of the communication and the rights of the informant under the terms set forth in this Privacy Policy.

4. PERSONAL DATA PROCESSED

As indicated in the previous section, STRATIO's Whistleblower Channel allows for the submission of anonymous reports.

However, if the informant wishes to submit the complaint in a nominative manner, STRATIO may collect, within the framework of a communication, the following types of data from the informant and, if applicable, from the persons involved in the communication:

Identifying data: name and surname.
Contact data: Telephone and e-mail.
Professional data: Professional position.

In addition, STRATIO may process other types of data based on the facts reported as allegedly criminal or irregular and the supporting documentation that may be appropriate to investigate the reported conduct.

No personal data will be collected if it is not directly relevant to the processing of specific information. In the event that irrelevant data is accidentally collected, such data will be deleted from the Whistleblower Channel without undue delay.

If it is proven that the information provided or part of it is not truthful, it will be deleted immediately as soon as this circumstance becomes known. In the event that this lack of truthfulness may constitute a criminal offense, the information will be kept for the necessary time during the legal proceedings.

5. PURPOSES OF DATA PROCESSING

STRATIO shall process the data to which it may have access as a result of the communications received for the following purposes:

Receive and decide on the admissibility of communications received through the Whistleblower Channel.
Once the communications have been admitted for processing, to carry out the investigation of the facts reported and to adopt, if appropriate, the pertinent corrective measures.
Keeping the complainant informed about the admission, or non-admission, of his or her communication for processing, as well as the progress and results of the investigation process in the event that there are sufficient grounds to admit his or her communication for processing.

6. LEGITIMACY FOR DATA PROCESSING

STRATIO has the following legitimate bases for the processing of data, in accordance with the conduct reported through this Whistleblower Channel:

Compliance with legal obligations applicable to STRATIO if the communication refers to breaches provided for in the Whistleblower Protection Act:
- Breaches of European Union law,
- Planning of crimes or serious or very serious administrative infringements of the Spanish legal system.
Legitimate interest of STRATIO in ensuring that corporate behaviors are respected, without the processing of data in this framework leading to an imbalance in the rights of the data subjects and without the processing being likely to cause them prejudice, if the communication concerns conduct contrary to STRATIO's Code of Ethics.
STRATIO's public interest if the communications made are carried out within the scope of public disclosure.

7. RECIPIENTS OF THE INFORMATION

The data to which STRATIO may have access as a result of the communications received through the Whistleblower Channel may be shared with:

Public bodies or institutions, judges and courts when necessary for the adoption of disciplinary measures, for the processing of legal proceedings which, where applicable, may be appropriate or in those cases in which it is legally required.
To the Public Prosecutor's Office, when the proceedings fall within its competence.

With regard to the communication of the informant's personal data, STRATIO shall guarantee that his/her identity, and any other personal data that STRATIO may have about him/her, shall in all cases be kept confidential and shall not be communicated to the persons to whom the facts reported refer or to third parties, respecting in all cases the fundamental rights of the individual, without prejudice to any actions that may be taken by the competent judicial authorities, as the case may be.

8. DATA RETENTION PERIODS

The personal data to which STRATIO may have access as a result of the communications received through the Whistle-blower Channel shall be processed for the time necessary to decide on the appropriateness of initiating an investigation into the facts reported and for the management of the communication, provided that the same is admitted for processing.

Specifically, STRATIO will process the personal data within a maximum period of three months from receipt of the communication, except in cases of particular complexity, in which case it may be extended for a further three months.

Once the aforementioned period has elapsed without any investigation proceedings having been initiated, the data shall be deleted from the communication system, except for the purpose of maintaining evidence of the operation of the system and in an anonymized form.

In the case of communications that have not been sent, they will be kept in an anonymized form, completely eliminating the personal data in order to be able to accredit the operation of the system, as well as for statistical purposes.

9. USER RIGHTS

The regulations of protection of the informant guarantee to the Users the following rights recognized in the regulations in the matter of protection of data that will be able to be exercised whenever they turn out to be of application:

Access : Allows interested parties to know what information is held, where it has been obtained, to whom it has been provided and for what uses it has been processed.
Rectification : Allows interested parties to rectify any erroneous or outdated data.
Deletion : Allows data subjects to stop the processing of their data.
Opposition : Allows data subjects to stop the use of their data for a specific purpose. In the case of the person to whom the facts related in the communication refer, it will be presumed that, unless proven otherwise, there are compelling legitimate reasons that legitimize the processing of their personal data.
Limitation : Allows data subjects to restrict the processing of their data, but in such a way that they are retained for some subsequent purpose.
Portability : Allows data subjects to obtain a copy of their data in electronic format and, in certain circumstances, to request that it be communicated to another service provider. It is only applicable for computerized processing carried out with the consent of the User or for the performance of a contract.
Revocation of consent: Allows data subjects to withdraw the consent, if any, given for the processing of their data.

However, the exercise of these rights is limited to those informants who have identified themselves at the time of submitting the communication. If STRATIO has reasonable doubts as to the identity of the informant requesting the right, it may request information that will allow STRATIO to prove his or her identity. Whenever applicable, the aforementioned rights may be exercised to STRATIO by mail to the above-mentioned address and to the attention of Mamen Franco or by e-mail to [email protected] .

If informants require further information in this respect or consider that their right to data protection has been violated, they may contact STRATIO's Data Protection Officer [email protected] or the Spanish Data Protection Agency ( www.aepd.es ).

10. ACCURATE AND TRUTHFUL INFORMATION

STRATIO informs the Whistleblower that the communication transmitted through the Whistleblower Channel may lead to the initiation of internal or external investigations and may have negative consequences for those affected.

For this reason, you should only provide us with information that you believe to be correct, to the best of your knowledge and belief, and that is relevant to the detection of a breach of regulatory compliance and/or STRATIO's Code of Ethics or Code of Conduct.

STRATIO may initiate any disciplinary and/or legal action it deems appropriate if the communication is manifestly unfounded or if, in STRATIO's opinion, there are reasonable grounds to believe that the information was obtained through the commission of a crime.