Nubhora’s Whistleblowing Channel
Nubhora’s Whistleblowing Channel is a tool that allows employees to alert an entity about conduct, facts or information that are considered to constitute a criminal infraction, a breach of the Code of Ethics or that are contrary to the policies and procedures established in the company, and that occur in the company by its staff and managers.
It is a secure and confidential means that allows, when deemed necessary, anonymous complaints to be made; Complaints whose plausibility will be analyzed, leading to the opening of the corresponding investigation procedures if there are sufficient elements or indications.
The Whistleblowing Channel is not:
- To provide suggestions, proposals, or other considerations.
- To generate unfounded or false conflict situations, since proof of the conduct or facts that are reported will be requested.
The company will not allow any type of retaliation to be adopted against whistleblowers who, in good faith, communicate through this channel facts that may be regulatory breaches in accordance with the provisions of current legislation.
The Nubhora Whistleblowing Channel will follow the following principles at all times:
Anonymity:
You will maintain your complete anonymity when submitting a report, unless you voluntarily provide personal information. It is not mandatory to provide any personal information.
Confidentiality:
Regardless of whether you decide to file the complaint anonymously or by providing personal data, confidentiality will be maintained throughout the procedure, without prejudice to legal obligations.
No retaliation: No
action will be taken against a whistleblower who makes a report based on truthfulness criteria.
On the contrary, the company will not tolerate the abusive use of this tool through its fraudulent use. In this way, the company will sanction any whistleblower who files false or reckless complaints.
Protection of Personal Data
The purpose of this whistleblowing channel is to manage the notification of complaints received, to carry out the investigation of the reported facts and to adopt the relevant corrective measures. The legal basis for the processing is the existence of a legal obligation, in the terms established in article 6.1.c) of the General Data Protection Regulation.
The data will be processed for the purposes indicated during the period necessary for its investigation in accordance with the provisions of current regulations.
At any time, you may exercise, provided that they are applicable, your rights of access, rectification, deletion, opposition, limitation and portability with respect to the personal data you have provided, through the channels established in the company.
If you consider that your right to data protection has been violated, you may file a complaint with the Spanish Data Protection Agency (www.aepd.es) or Inology’s Data Protection Officer (rgpd@inology.com).
