Faro Barcelona Informant Channel
The values of FARO BARCELONA are the foundation of our business: integrity, professionalism, and transparency; respect and rigor are our raison d'être. In our company, compliance with legal and regulatory requirements is essential in all areas of our daily activity. In order for anyone, including employees, internal and external collaborators, and other stakeholders, to report in good faith any violations they detect in relation to FARO BARCELONA's activity, we provide the Company Informant Channel. The channel is available 24 hours a day, 365 days a year, through the following access means (to the extent possible, please specify which entity or business your report pertains to).
In compliance with the provisions of Law 2/2023, of February 20, regulating the protection of individuals reporting regulatory violations and combating corruption, FARO BARCELONA has implemented an Internal Information System.
This system aligns with the purpose of the aforementioned Law, allowing individuals referred to in Article 3 to report on actions or omissions outlined in Article 2, primarily violations of EU law and serious or very serious criminal or administrative offenses, while being protected against potential retaliation.
FARO BARCELONA's Internal Information Channel enables the reporting of such violations in writing or via voice message using a telematic system through a computer application that ensures the protection of the informant's identity, the confidentiality of the information, and data protection. Among the informant protection measures, there is the option to submit information anonymously or to waive communication with the System Manager after providing the information.
The submission of the communication must be accompanied by appropriate supporting evidence, meaning verifiable data and, if necessary, documentation considered necessary to substantiate the reported information.
The informant must anonymize documents and data related to the communicated information to ensure proper confidentiality, except for those that are minimally necessary to conduct the investigation.
Information submitted through this Channel must be limited to the violations established in Article 2 of Law 2/2023.
External information channels
FARO's informant Channel is the preferred channel for reporting potential breaches related to the Company. However, and especially in cases where the violation cannot be effectively addressed or if the informant believes there is a risk of retaliation, there are also external information channels available to the competent authorities and, where applicable, to institutions, bodies, or agencies of the European Union, for use by informants.
In this regard, information can be provided through the following external information channels:
In the case of the Autonomous Community of Catalonia, through the information channel made available by the Anti-Fraud Office, the body that assumes the functions of an Independent Authority for informant Protection.
Principles and Procedure of the informant Channel
Object and principles, procedure, and Privacy of the informant channel.
This document aims to provide information on the Procedure and Privacy of the informant Channel, or Ethical Channel (hereinafter the "Channel").
In line with best practices and with the aim of complying with legal regulations, we have decided to establish a system for both the submission and management of complaints, claims, or reports related to alleged irregular or reprehensible conduct by members of our entity. Therefore, we provide this Channel for the communication of such matters.
Based on Law 2/2023, of February 20, regulating the protection of individuals reporting regulatory violations and combating corruption, in its transposition into Spanish law from Directive (EU) 1937/2019 of October 23, 2019, better known as the "informant law," and taking into account the General Data Protection Regulation 2016/679 (GDPR) and Organic Law 3/2018 of December 5 on the protection of personal data and the guarantee of digital rights, we implement the following internal reporting method, which includes aspects such as accepting anonymous reports, the option to preserve the identity and confidentiality of data of the individuals involved in the reporting process, especially the data of the person who reported the facts if they had chosen not to do so anonymously.
- Good faith communications. Users of the Channel must use it responsibly, and unfounded or malicious reports are not allowed, and legal and/or disciplinary actions may be taken if applicable.
- Furthermore, the presentation of facts by the reporting party must be respectful and in accordance with the required decorum. The Organization is not responsible for derogatory comments that the reporting party may make about anyone.
- Procedure of the informant Channel
- Minimum content of the report
- Protection of the informant
- Personal data
As part of the implementation of the Regulatory Compliance system, our entity provides all users with a informant Channel, with the aim of preventing and detecting any irregular, illegal, or criminal behavior. Through this channel, employees, suppliers, customers, collaborators, or anyone who wishes to do so can report any situation or indication that implies the commission of a crime or a violation of current legislation. This channel, in addition to serving to report possible irregularities, is an essential tool to ensure the full validity of the Code of Ethics and/or Code of Conduct and to enable continuous improvement of prevention protocols, transparency rules, and other internal regulations.
Please read carefully before proceeding with the communication, and we remind you of the option to make the communication verbally, for which you can request an appointment through the same form, for which your contact details are essential.
2. informant Channel Procedure
Once the communication is received, the responsible department will verify the absence of incompatibility and open the file, deciding in a reasoned manner whether it is necessary to conduct an investigation or whether it should be archived due to its irrelevance or limited credibility.
- Within 7 days, a notification will be sent to the person who made the communication, using the provided contact details or through the platform in the case of anonymous communication.
- The responsible department will appoint an investigator, who may be internal or external, single or multiple, depending on the needs of the case. In addition, the Committee may take precautionary measures to protect the informant, prevent the continuation of illegal activities, prevent the destruction of evidence, and avoid serious or irreparable harm.
- After conducting the investigation, the investigator will prepare a report with conclusions, indicating whether it is appropriate to recommend sanctions and measures.
- The report will be submitted to the Decision-Making Body, which may vary depending on the seriousness of the facts and the individuals involved. The designated Body may be the Ethics Committee or the Board of Directors. Once the case has been reviewed and evaluated, sanctions and measures will be taken for justified reasons.
- A response must be provided within three months.
3. Minimum content of the report:
- Choose a reference for the file in order to make future inquiries anonymously and receive the results of the investigation.
- Concise presentation of the facts, arguments, and/or evidence.
- Individual or group considered possibly responsible for the irregularity.
- Name and surname and contact method in case of wishing to be informed.
4. Protection of the informant
The entity will establish all necessary measures to protect the informant from any form of retaliation, such as suspension, dismissal, removal, or equivalent measures; demotion or denial of promotions; refusal of training, evaluation, or negative references regarding their job performance, etc. Support measures, such as free information and advice, will also be implemented. Protection measures against retaliation, such as the attribution of responsibility for the acquisition or access to the communicated/revealed information, will be taken.
5. Personal data
ACCESS THE FARO BARCELONA INTERNAL INFORMATION CHANNEL