DPM Finanzas EAF's anonymous communication channel

Start

Step 1/5 Categorize concern

To facilitate the subsequent management of your communication, help us to categorize it as best as possible.

What category does your communication fit best?

Abuse of power

Bribery

Conflict of Interest and Market Abuse

Corruption in business

Discovering and disclosing secrets

Ethics and Integrity

Fraud

Influence trafficking

Issues related to human resources

Legal duty of confidentiality

Misleading advertising

Money Laundering and Terrorist Financing

Protection of personal data

Scam

Sexual Exploitation, Abuse, or Harassment

Others

Do you suspect any of the following people?

CEO

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 provide your personal data, you can do so by stating that you want the communication to be anonymous.

What is your relationship with the company?

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 maximum detail the fact you want to report, detailing as much information as possible and attaching, if any, evidence.

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 final step of the process, you must provide a secret password that only you will know. This password, together with the identification code that we will provide at the end, will be the only means by which you can follow the progress of your communication.

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 already entered all the information needed to start the communication management process.

The information is ready to begin the process of purging responsibilities. The affected persons or events will be investigated and the resulting actions will be carried out.

The informant undertakes to the veracity of the data provided in this communication. Otherwise, the company reserves the right to take legal action against you.

This is the last form of the process, when you click Submit, the investigation will begin, and within a maximum period of 3 months, the resolution of your communication will be carried out, which will be reflected on the platform.

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 DPM Finanzas EAF

Introduction

Confidentiality and security are paramount values for DPM FINANZAS EAF, SL and, consequently, we are committed to guaranteeing the User’s privacy at all times and to not collecting unnecessary information. In general, regarding forms where fields are marked as mandatory, these must necessarily be completed in order to process your requests.

This Privacy Policy may be modified to adapt to changes that occur on our website, as well as to legislative or jurisprudential changes regarding personal data that may arise; therefore, it requires reading every time you provide us with your data through this Website.

Below, we provide all the necessary information regarding our Privacy Policy in relation to the personal data we collect, explaining: who is the data controller, for what purposes we collect the data requested, what is the legitimacy for its processing, how long we keep it, to which recipients your data is communicated, and what your rights are.

Who is the data controller?

The Internal Information System Manager (Responsable del Sistema de Información) and the Data Controller regarding the information obtained from reports and corresponding inquiries is the entity DPM Finanzas EAF, S.L. , with registered office at C/ Zurbarán 8, 4ª planta, 28010 Madrid, Spain . You may contact the Data Protection Officer (DPO) of DPM Finanzas at [email protected] .

What data is processed?

The data processed is that included in the information submitted through the channel enabled for this purpose, as well as that derived from any internal investigations to which it may have given rise.

Likewise, we inform you that the personal data processed typically corresponds to the following categories:

Contact data.
Sensitive or highly personal data: Reports and results of investigations carried out within the framework of the Internal Information Channel.
Identification data: Name and surname(s), where applicable.
Special categories of data: (For example, data relating to health, sexual life or orientation, ethnic or racial origin, political opinions, and philosophical or religious beliefs).

In the event that the report is made verbally through the pertinent channels, it will be documented by means of recording or transcription. The informant may check, rectify, and accept the transcription of the conversation by means of their signature.

For what purposes will your data be processed?

The data obtained from communications, reports, or investigations carried out through the Whistleblowing Channel (Canal de Denuncias) will be processed for the handling thereof, the investigation of the reported facts, and for the prevention of the possible commission of criminal offenses or infractions of the Internal Code of Conduct by employees or collaborators of the company, in accordance with the requirements of Law 2/2023 . The management thereof includes the receipt of alerts and the investigation of the reported facts.

To whom may your data be communicated?

In general, this information will only be accessed by the System Manager and the persons indicated in the Information Management Procedure.

Access to data received through the Internal Information System is limited to:

The System Manager and whoever manages it directly.
The Human Resources manager or the duly designated competent body, only when the adoption of disciplinary measures against an employee may be appropriate.
The entity's legal services , if the adoption of legal measures in relation to the facts recounted in the communication should be appropriate.
The Data Protection Officer (DPO) .
External advisors or providers , when their intervention is necessary for the management of the Internal Information System. In these cases, the corresponding confidentiality agreement or data processing agreement will always be formalized.

Competent administrations or legal entities, attorneys in charge of the matter, and judges and courts may also have access.

Furthermore, access to data is foreseen for persons other than those provided for in Article 32.1 of Law 2/2023 , of February 20 (regulating the protection of persons who report regulatory infractions and the fight against corruption), or even its communication to third parties, when necessary for the processing of sanctioning or criminal proceedings that may, where appropriate, be applicable.

How long will your data be kept?

The data subject to processing will be kept in the information system only for the time strictly necessary to decide on the appropriateness of initiating an investigation into the facts contained in the received report. In this scenario, the information will be kept for the time necessary for the processing of the judicial procedure.

In any case, three months after the receipt of the report , if no investigation proceedings have been initiated, the data will be deleted, unless the purpose of conservation is to leave evidence of the functioning of the system.

The personal data included in the record book (libro-registro) provided for by Art. 26.1 of Law 2/2023 , of February 20, will only be kept for the period that is necessary and proportionate for the purposes of complying with this law. In no case may the data be kept for a period exceeding ten years .

Communications that have not been acted upon may only be recorded in anonymized form, without the blocking obligation provided for in Article 32 of Organic Law 3/2018, of December 5, being applicable.

Finally, we inform you that personal data whose relevance is not manifest for handling specific information, and data collected by accident, will be deleted without undue delay, unless the lack of truthfulness may constitute a criminal offense.

What are your rights?

Any person may withdraw their consent at any time, when said consent has been granted for the processing of their data. In no case does the withdrawal of this consent condition the execution of the subscription contract or relationships generated previously.

Likewise, you may exercise the following rights:

Request access to your personal data or its rectification when it is inaccurate.
Request its erasure when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
Request the limitation of its processing in certain circumstances.
Request opposition to the processing of your data for reasons related to your particular situation.
Request the portability of the data in the cases provided for in the regulations.
Other rights recognized in the applicable regulations.

Where and how to request your Rights: By means of a written request addressed to the controller at their postal address or via email at [email protected] , indicating the reference "Personal Data" ("Datos Personales"), specifying the right you wish to exercise and regarding which personal data.

In case of divergences with the company in relation to the processing of your data, you may file a complaint with the Data Protection Agency (www.agpd.es).