Pino Martínez S.L. 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?

Consumer protection

Environmental Protection

Protection of personal data and privacy

Public health

Security of networks and information systems

Transportation security

Others

Do you suspect any of the following people?

Engine Equipment

Flow Office Purchasing Team

Flow Team Factory Coordination Conservation Maintenance

Flow Team Factory Coordination Manufacturing

Flow Team Factory Coordination Warehouse Conservation

Flow Team Office Administration

Flow Team R&D Office

Foreign Commercial Team

Foreign Loyalty Team

Human Resources Office Flow Team

National Commercial Team

National Loyalty Team

Team D

Training and Team Supervision

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

Have you discussed this with any member of management?

Yes

I do not remember

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.
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 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 Pedro Pino Martínez S.L.

Table of contents:

1. Definitions.

2. Purpose.

3. Purpose.

4. Infringements covered by this policy.

5. Scope of application.

6. Internal Information Channel.

7. Responsibility for the complaints channel.

8. Measures for the protection of the complainant.

9. Protective measures for the respondent.

10. Data protection.

11. Adoption, publication and entry into force.

1.-Definitions

- Internal Reporting Channel (also Internal Communication Channel) - Means of communication with the organisation through which information can be brought to the attention of the person specially designated by the person responsible for the Internal Reporting System for the purpose of initiating an investigation, if appropriate.

- Information - Communication that warns of any active or omissive conduct that may constitute any of the infringements that make up the objective scope of application of this policy.

- Whistleblower - Any person belonging to the organisation or falling within the subjective scope defined by this policy who reports information in good faith.

- Person appointed by the Internal Information System Manager - Person appointed by the Internal Information System Manager to be responsible for the direct management of the Information System and the processing of files.

- Information management procedure - A set of rules established within the organisation for the receipt and processing of information in order to initiate an investigation, if necessary.

2.- Purpose

The Pedro Pino Martínez, SL whistleblowing channel allows you to confidentially, but not anonymously, inform the person in charge of said channel of any allegedly criminal or fraudulent act.

3.- Essential principles

The following principles and guarantees shall apply in the procedures for receiving complaints and in the internal investigations arising therefrom:

1 - Anonymity - Whistleblowers will be assured of the possibility to make anonymous complaints.

2 - Confidentiality - The persons responsible for the management of the whistleblowing and investigation processes must observe the strictest secrecy regarding the identity of whistleblowers and defendants, when they have knowledge of said identities. Exceptions are made for communications necessary for the performance of the functions established in this Policy or at the request of the judicial authorities.

3- Speed - Unwarranted delays in the investigation process should be avoided

4 - Presumption of innocence of persons under investigation, as well as the right to defence and the right to contradict facts and arguments.

5 - Objectivity and autonomy - Avoiding any kind of internal or external interference and ensuring that there is no conflict of interest.

4.- Infringements covered by this policy.

Possible offences that can be reported are those related to the following offences:

· Bribery offence

· Offence of counterfeiting credit or debit cards.

· Offence of insider trading

· Intellectual and industrial property offences

· Town planning offences

· Scam

· Fraud against the Public Treasury

· Social Security fraud

· Non-compliance and false accounting obligations

· Punishable insolvencies

· Misleading advertising

· Company secret

· Non-compliance with the Code of Good Governance.

· Non-compliance with conflict of interest policy

· Non-compliance with information systems security regulations.

· Any other type of non-compliance, misconduct or work related, criminal or administrative offence, as considered by the informant.

5.- Scope of application

Objective scope : The queries or complaints processed through the Whistleblowing Channel will deal with possible criminal, civil, commercial, administrative and tax infringements attributable to the legal identity. Queries or breaches related to strictly labour issues or corresponding to the ordinary management of customer services or after-sales services will not be processed through the Complaints Channel. Such queries and breaches must be reported through the channels and procedures established for this purpose.

Subjective scope : The Whistleblowing Channel is available to both company employees and third parties, all of whom are permitted to submit, with full confidentiality, queries about the company's regulations, as well as reporting possible breaches or violations thereof.

Employees are understood to be all administrators, managers and employees of the company Pedro Pino Martínez, S.L. regardless of the country or territory in which the complaint, non-compliance or commission of the conduct takes place.

6 .- Internal Information Channel

The website of the company Pedro Pino Martínez, S.L. contains the Ithikios software for processing the complaint.

Access to the channel is via the livingpino.com website where a link called "Whistleblower Channel" code can be used to access the Company's whistleblower channel software. It is multilingual.

The channel allows for 3 main actions:

a) Raising a complaint

The information will be entered in several steps so that the complainant can classify the communication according to the categories established by the company. Customised fields can be added according to complaint category, as well as attachments of supporting documents and images.

The report can be anonymous or not, but they will always be confidential. If it is not anonymous, you can configure whether or not you want to validate the email.

Subsequently, the data privacy clause must be accepted.

When you start a new communication, you enter the basic data. Documents can be attached.

b) Check complaint status

When a report is made, the informant receives secret codes that allow him/her to communicate anonymously with the company. From this area, he/she can consult the status of the report at any time and answer any questions that the company may request in order to be able to make the communication correctly.

The platform generates a certificate with all the communications made to guarantee the informant the traceability of the information exchanged.

c) Ask questions / make suggestions.

With regard to the receipt of complaints , once the complaint has been received, the person appointed by the company to process the complaint will be notified by e-mail to connect and process the complaint.

This person shall examine and assess the admissibility of the communication and, if necessary, initiate an investigation. That person shall conduct an investigation of both the facts and the persons concerned by the communication, informing them of the acts or omissions attributed to them and giving them the right to be heard.

Finally, once the investigation has been carried out by the person in charge, a resolution proposal is made.

In the event that the decision is rejected, the complaint will be registered and filed.

In the event that the agreement is upheld, it shall be brought to the attention of the Administrative Body so that it can apply the appropriate disciplinary measure to the accused, or so that it can adopt the appropriate measures with respect to the accused, in the event that he/she is not an employee of Pedro Pino Martínez, S.L., but rather an external collaborator or supplier. All of the above without prejudice to its communication to the competent public authorities, if necessary.

All resolutions shall be duly and sufficiently reasoned.

7.- Responsibility for the whistleblowing channel

The Board of Directors of Pedro Pino Martínez S.L. has appointed DOÑA INES PINO OBRERO as the person responsible for the management of complaints made through the Complaints Channel that may be filed by employees of Pedro Pino Martínez S.L. or third parties. In the event of absence at the time of processing the complaint it will be Don Manuel Rodríguez Fragueiro who will assume this function.

8.- Whistleblower Protection Measures

Prohibition of retaliation: Whistleblowers who report in good faith will be protected against any kind of discrimination and penalisation on the basis of the reports made.

The prohibition of retaliation provided for in the preceding paragraph shall not prevent the adoption of appropriate disciplinary measures when the internal investigation establishes that the communication is false and that the person who made it is aware of its falsity.

9.- Measures for the protection of the defendant

The respondent shall be guaranteed the following rights:

a) Right to protection during the course of the investigation.

Pedro Pino Martínez S.L. will provide the reported person with the full guarantee of their rights as any employee, and no sanctioning or legal measures will be applicable until the truthfulness of the reported facts is verified, the relevant evidence is gathered, and the concurrence of a criminal act or an act contrary to the principles and values of the entity of Pedro Pino Martínez, S.L. is concluded.

b) Right to receive information.

The accused must be informed of the investigation process that is being carried out, so that, faced with the accusation of such conduct, he/she can exercise his/her right of defence and allege everything that allows him/her to prove his/her innocence. The information provided to the accused must be in terms that protect the confidentiality of the whistleblower. On the other hand, in cases where the information in the investigation process poses a significant risk to the ability to investigate effectively, communication to the respondent may be delayed for as long as such a risk exists. The aim is to avoid the destruction or alteration of evidence by the respondent.

c) Right to confidentiality.

Throughout the investigation of the complaint, the defendant shall be guaranteed the right to confidentiality of his or her personal data, in order to avoid any dissemination of information that could affect his or her reputation.

d) Right to a transparent investigation.

The respondent shall have the right to an investigation based on an objective analysis of the evidence gathered, ensuring an effective and transparent investigation.

10.-Data protection

All personal data provided for the purpose of placing a complaint will be processed in accordance with data protection regulations, for legitimate and specific purposes in relation to the investigation that may arise as a result of the complaint. Under no circumstances will personal data be used for other purposes, and their processing will always be appropriate and proportionate to the aforementioned purposes.

This Policy shall at all times comply with the legal requirements in force regarding data protection, and shall take into special consideration the guarantees established in Organic Law 3/2018, of 5 December, on the protection of personal data and guarantees of digital rights and the Regulation (EU) of the European Parliament and of the Council, of 27 April 2016, on the protection of natural persons.

11.- Approval, publication and entry into force

This Policy has been approved by the Board of Directors of the company Pedro Pino Martínez SL on 8 May 2024 and comes into force at this very moment.

This Policy is published on the Company's website and will be sent to the Company's personnel and to third parties with whom the Company has dealings.

This Policy will be reviewed, updated, approved and disseminated periodically and as necessary to make any changes.