WHISTLE-BLOWER’S CHANNEL

EQUIMODAL is fully committed to the highest standards as regards ethics and regulatory compliance in relationships with all its partners, workers, collaborators, customers, suppliers, and interest groups, in all the activities that it carries out.

To ensure that the criminal-risk management and regulatory-compliance system is maintained, EQUIMODAL’s Board of Directors has appointed and empowered a Compliance Committee made up of internal experts who are constantly advised by an external firm that specialises in managing corporate risk.

In accordance with the Criminal-Risk Management System Manual, the Regulatory Procedure for the activity and functioning of the Compliance Committee, and the Whistle-Blower’s Channel Management Procedure, EQUIMODAL’s Compliance Committee has, inter alia, the functions of managing the Whistle-Blower’s Channel, being able to outsource part of that management to an external adviser, and investigating possible cases of conduct that is unlawful or contrary to ethics and of which it has become aware by other means.

EQUIMODAL’s partners, workers, management teams. collaborators, customers, and suppliers, as well as any of EQUIMODAL’s members concerned, can use that ethics channel confidentially to:

  • Raise any query regarding interpretation of the Code of Conduct, as well as of the legislation and internal regulations applicable to EQUIMODAL’s corporate Regulatory Compliance.
  • Notify cases of non-compliance with the Code of Conduct as well as with the legislation and the applicable internal regulations.

Queries and notifications of non-compliance must be made using the following form. All queries and notifications will be answered and resolved. However, anonymous queries will not be answered.

Under no circumstances shall information concerning the progress and result of investigations be provided to whistle blowers, who shall be treated with absolute confidentiality. EQUIMODAL’s Code of Conduct guarantees that there shall be no reprisal as the result of any query or notification of non-compliance made in good faith.

Making a denunciation or query

    (*) DNI – NIF: Documento Nacional de Identidad – Número de Identificación Fiscal (National Identity Document – Tax Identification Number)

    Please set out in this box all the details of the query or denunciation that you wish to make to the Compliance Committee. Please be as specific as you can, providing information that you consider relevant for proper resolution. You can add files to supplement the information ADD FILE.

    Files:

    From the following categories, please choose the one that you feel best matches your communication:

    BASIC DATA-PROTECTION INFORMATION

    Data controller:

    EQUIMODAL, SL. CIF (Código de Identificación Fiscal – Tax identification Code): B-50534205. Domicile: Nave 12, Calle E-12, Polígono Industrial Malpica, 50007 Zaragoza.

    Purpose of processing:

    Data are processed only by EQUIMODAL’s Compliance Committee in order to handle, investigate, and / or resolve related queries and / or notifications of irregularities or denunciations of non-compliance with the Code of Conduct and the Criminal-Risk Prevention Policy, or of facts or omissions that may constitute breaches of current legislation, or cases of non-compliance with the values and action guidelines set out the Code of Conduct, the Criminal-Risk Prevention Policy, and the remaining internal regulations of EQUIMODAL’s Criminal-Risk Management System, guaranteeing complete confidentiality and safe-keeping under security measures.

    Types of data:

    Identifying data, and, depending on what the user indicates in her / his request or attached file, specially-protected data may be contained therein.

    Legitimacy:

    EQUIMODAL’s legitimate interest in fulfilling requirements in matters of legal and regulatory compliance, particularly those relating to the possible criminal liability of the legal person.

    Recipients:

    Your data can be passed on to third parties only in the case of professional experts and in the case of criminal denunciations, with the aim of maintaining the highest level of confidentiality and encouraging the use of this channel.

    Period of storage:

    For as long as the data subject does not request deletion of her / his data, and for the necessary periods during which the data must be made available to the competent Authorities.

    Exercising rights:

    By writing to the data controller’s physical address, or by sending an e-mail message to e.fortun@equimodal.com, attaching a copy of your DNI or other identification document and quoting “Ref. Personal Data – EQUIMODAL Ethics Channel” for those rights to be handled by the Compliance Committee). If the exercise of your rights is not dealt with, you can make a complaint to the Agencia Española de Protección de Datos Spanish Data-Protection Agency (www.agpd.es).

    More information:

    Privacy policy

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