Related documents | VINTEGRIS | |||||||||
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Brief description | This Strategy complies with Law 2/2023, of
February 20, regulating the protection of
people who report regulatory violations
and the fight against corruption. It establishes the
principles and functioning of an Internal System
Information (SII) that the entity makes available
of the persons that the aforementioned Law recognizes under its
personal scope of application, to inform of
any behavior that involves certain
infringements of European Union regulations or
may constitute a criminal offense or
serious or very serious administrative offenses, as well as any
behavior not aligned with the Code
Organizational Conduct and Policies.
This system protects those who choose to report
good faith, as well as to those affected against whom
make false, distorted or
deliberately malicious or based on
information obtained illegally. | |||||||||
Related documents | This Strategy is a local regulation and
complements with:
– VINTEGRIS Code of Conduct
– Complaints Channel and Management Procedure
of the Internal Information and Protection System
to the Informant
– Protocol prohibiting reprisals | |||||||||
Date of last update | 28/02/2024 | |||||||||
Latest version | 28/02/2024 | |||||||||
Date of adoption | 28/02/2024 | |||||||||
On the occasion of the entry into force of Law 2/2023, of February 20, regulating the protection of persons who report on regulatory infringements and the fight against corruption, VÍNTEGRIS, SLU, (“VÍNTEGRIS” or the “Company”) approves this Internal Information and Whistleblower Protection System Strategy (hereinafter, the “Strategy”) framed within the Company’s Regulatory Compliance Model.
2. Object and scope of application
This Strategy demonstrates VÍNTEGRIS’ commitment to Regulatory Compliance, ethics and dialogue, fostering a culture of active listening with its stakeholders, both internal and external.
The Strategy aims to guarantee the protection of informants against possible reprisals and to state the general principles of the Internal System of Information and Protection of the Informant (hereinafter, the “SII” or “System”).
The SII of VÍNTEGRIS integrates the Complaints Channel or Internal Channel, as the preferred mechanism for communication, consultation or reporting of irregularities.
This Strategy and the SII described herein will be applicable to VINTEGRIS, as well as to:
Information received through the SII will be managed and investigated in accordance with the Internal Information System Management and Informant Protection Procedure.
VÍNTEGRIS also has a Retaliation Prohibition Protocol that establishes the necessary provisions for the SII and existing internal information channels to comply with the requirements established in current legislation.
The main elements of the SII are described below in a summarized question-and-answer format to facilitate understanding.
The VÍNTEGRIS Whistleblowing Channel, also known as the Internal Channel (accessible via the following link: https://vintegris.bizneohr.com/whistleblowing) , is the preferred channel for VÍNTEGRIS employees and any related third parties to raise concerns about potential violations so they can be investigated and, where appropriate, addressed. This channel is available to all employees, as well as to third parties with whom VÍNTEGRIS interacts on the aforementioned website.
The SII also offers the following communication channels:
The VÍNTEGRIS Whistleblowing Channel is a channel that guarantees the confidentiality of all communications received.
Yes, it is possible to report anonymously. However, since it is often useful to have a way to contact informants for more information, it is advisable to provide some contact information (a phone number or email address).
Some examples of infractions that may arise are:
The Internal Channel should not be used:
VÍNTEGRIS’s own Reporting Channel provides guidance on the information to provide. Generally speaking, it is advisable to submit as much information as possible so that VÍNTEGRIS can assess and investigate the facts, such as:
A communication can only be tracked if it contains information detailed enough to allow an investigation to be carried out.
When submitting a communication, the Informant will receive an acknowledgment of receipt within seven calendar days.
Next, the VÍNTEGRIS Internal Channel Manager will analyze and evaluate the facts and evidence contained in the report on a preliminary basis. For this purpose, the informant—if they have provided contact information—may be asked to supplement or clarify the information provided, supplying any additional documentation necessary to substantiate the alleged infraction. As a general rule, the matter can be expected to be investigated within three months.
If deemed appropriate, the general conclusions of the investigation, once it is completed, will be shared with the Informant, respecting at all times the rights of confidentiality, privacy, data protection and the rights of all those involved.
It is also possible to ask questions or request a meeting with the Head of the VÍNTEGRIS Complaints Channel, who will provide advice with complete confidentiality and will respond to the meeting request within a maximum of 7 days.
The Internal Information System – through the VÍNTEGRIS Whistleblowing Channel – should be used primarily for reporting, as this facilitates a swift, diligent, and effective response. Notwithstanding the above, any employee may report violations falling within the scope of Law 2/2023 to the competent authority through external reporting channels, such as the Independent Whistleblower Protection Authority.
The basic principles of action on which this Strategy is based are detailed below:
Notwithstanding the foregoing, the mere communication of an Infringement does not exempt the Informant who participated in the reported misconduct from responsibility, although VÍNTEGRIS may take into account the notification of the Infringement when determining the measures to be taken.
Anyone who believes they are a victim of intimidation or retaliation should immediately report it through the communication channels enabled within the SII, preferably using the VÍNTEGRIS Complaints Channel.
The System will also allow the submission of anonymous communications, although we encourage Informants to provide identifying or contact information in the communication, as this allows for better and more efficient management of the communication.
The above safeguards also apply to related individuals who, in good faith, assist or support you in communicating your concern, such as colleagues and family members. However, this protection will not apply if you report a concern or breach that you know to be false or illegally obtained.
Respect for fundamental rights: The System guarantees the right to information, the right to a defense, the right to challenge evidence, the right to the presumption of innocence, and the right to honor for all persons involved in the proceedings. These persons also have the right to be heard at any time, in the manner deemed appropriate, to ensure the proper conduct of the investigation.
Personal data protection: VÍNTEGRIS undertakes to process at all times the personal data provided through the Complaints Channel and derived from the management and/or Instruction of the Information and investigations carried out, complying with the provisions of current legislation on data protection and, in particular, as provided in Title VI of Law 2/2023.
The person responsible for the internal information system of VÍNTEGRIS in Spain will be the Head of Human Resources of VÍNTEGRIS (“System Manager”), who was appointed by the CEO of VÍNTEGRIS, SLU on February 28, 2024.
The provisions of this Strategy constitute the minimum regulations applicable within the framework of the Regulatory Compliance Model of VÍNTEGRIS, SLU, without prejudice to applicable local legislation. The Principles and Guarantees of this Strategy are intended as interpretative principles. However, in the event of any conflict between this Strategy and local legislation, local legislation shall always prevail.
The CEO, as the highest governing body of VÍNTEGRIS, is responsible for the implementation of the Internal Information System and the supervision of this Strategy.
This Strategy is mandatory for all VÍNTEGRIS employees. Failure to comply (whether due to gross negligence or intentionally) will result in appropriate disciplinary action, which, depending on the circumstances, may include dismissal.
This Strategy has been approved by the CEO of VÍNTEGRIS, SLU, on [date]
February 28, 2024, entering into force on February 28, 2024, and will remain
This policy will remain in effect until any modification is made, which will be duly communicated.
This Strategy will be published on the VÍNTEGRIS corporate website. It will also be sent to VÍNTEGRIS staff and, where applicable, communicated to third parties with whom VÍNTEGRIS interacts.
Likewise, at the beginning of the professional relationship with VÍNTEGRIS, each new employee will be informed of it and of the existence of the VÍNTEGRIS Whistleblowing Channel as part of their initial training.
Likewise, training will be provided to managers and executives on how to identify and manage reports of violations, as well as their roles and responsibilities within the Internal Information System.
This Strategy will be reviewed, updated, approved and disseminated periodically and whenever it is necessary to make any modifications.
Version Number | Effective date | Approved by (Name and position) | Approval Date | Description | Author (Name and position) | 1 | 28/02/2024 | Matthew Walsh, Chief Executive Officer | 28/02/2024 | Vintegris’ internal information and whistleblower protection system strategy | Noemí Cruz, Head of the Internal Information System |
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“Affected” any person to whom an infringement is attributed in the communication made through the VÍNTEGRIS Complaints Channel or other channels.
“Informant” any person who makes a communication of a possible infringement through the VÍNTEGRIS Reporting Channel or through other means or communication channels enabled by VÍNTEGRIS.
“Infringement” means any indication or reasonable suspicion of non-compliance with the Code of Conduct, this Strategy, any other internal regulations of VÍNTEGRIS or current legislation.
“Instruction” or “Investigation” refers to all actions aimed at verifying the veracity of the reported facts.
“Affected Persons” any person referred to in a communication, other than the Informant or Affected Person.
“Strategy” this policy or strategy for protecting the Informant and the Internal Information System of VÍNTEGRIS.
“Procedure” the Internal Information and Whistleblower Protection System Management Procedure
“Employee(s)” means any person who provides services to VÍNTEGRIS through an employment contract, regardless of the type of contract, and the Company’s directors.
“Head of Internal Channel and Internal Information System” responsible for the internal information system of VÍNTEGRIS.
“Internal Information System” system that integrates all of the Company’s information channels, including the VÍNTEGRIS Complaints Channel.
“Third parties” are people linked to VÍNTEGRIS in their capacity as, for example, suppliers, contractors, subcontractors, collaborators, and former employees, people in selection processes and people in practical training without an employment relationship.
“Víntegris, SLU”, CIF: B-62913926 Reg. Merc. Barcelona, Volume 34720, Folio 177, Sheet No. B256168, Inscp. 34th
C. Pallars, 99 Floor 3 Office 33 08018
Barcelona Tel: +34 93 432 90 98
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