Rules on use of the ethics channel
This information channel is available to comply with the regulation on the protection of persons who report breaches of European Union Law.
It is important to understand that, what the above regulation seeks to preserve is the protection of the reporting person from possible retaliation in the employment or professional relationship in whose context a breach in Polymat takes place, which it or its employees or management may have committed, in the areas outlined below and that are liable to constitute a serious or very serious criminal or administrative offence or that affect the general interest.
When you use this channel, you are accepting that you have read and accepted the rules on use described here and the data protection conditions set out on this Website.
It is a secure and strictly confidential channel where communications can be made completely anonymously by following the steps described in this document.
Before providing any information to this channel, it is important to read and accept the following:
- Internal and external fraud,
- Discrimination, workplace and sexual harassment,
- Acts of corruption and bribery, money laundering,
- Offences and infractions against the Social Security and the Public Treasury,
- Infractions of labour law regarding Health and Safety at Work,
- Breaches of the regulations on privacy and personal data protection, security of network and information systems,
- Any other conduct that implies the commission of a serious or very serious offence or administrative infraction.
2. This channel has not been enabled to communicate violations of rules of private law which govern the relationships between private individuals and that do not affect the proper operation of public and private entities, such as complaints about service, to make claims, disseminate rumours, etc.
3. Information you provide must be based on good faith as the law does not protect someone who provides false information or information obtained unlawfully.
4. The provision of personal data is the full responsibility of the reporting person, who must comply with the regulations in that regard. Equally, the reporting person is responsible for the confidentiality and custody of the information provided by Polymat to the assigned identifying code.
5. You shall find detailed information regarding the processing of your personal data in the Ethics Channel Privacy Policy.
6. If you so wish, you may provide information anonymously; if, when making the communication, you identify yourself or give an address, email or safe place to receive notifications, we shall send you an acknowledgement of receipt within seven calendar days following receipt, unless this puts the confidentiality of the communication at risk.
In this case, the reporting person may create an email address with a fictitious name (and send it via a wifi connection that is not their own), for example: in Google, in the following way:
https://support.google.com/mail/answer/56256?hl=es
The email address that is created anonymously shall be used to be able to contact the reporting person in order to gather more information on the case.
Whether you identify yourself or not, we recommend that you provide a means to maintain communication with you or to ask for further information in order to be able to process the investigation, if applicable, and also to be able to notify you regarding actions or omissions attributed to you, and so that you can exercise your right to be heard at any time.
7. The manager of the Ethics Channel internal information system in Polymat shall send you information on the report to the address used, with a code with which you can consult the status of your communication.
8. The report shall be received by the manager of the Ethics Channel Internal Information System. We shall protect the identity of the reporting person. Said identity shall not be subject to the right of access to personal data and shall only be communicated to the judicial authority, Public Prosecutor’s Office or competent administrative authority, with the requirement that, in any event, third parties shall be prevented from accessing it. Under no circumstances shall the person to whom the reported facts refer be informed of the identity of the reporting person or, if applicable, of whoever made the disclosure public.
We shall also protect the information of the persons to whom the reported facts in the communication refer considering the risk that the information, even with apparent signs of truthfulness, may have been manipulated, be false or be motivated by something that the Law cannot protect. In these cases, the reporting person has sole and exclusive responsibility, which they must meet in any event, exempting the parent body as well as the internal information system manager.
Access to our internal information system is restricted to the System manager. Others who shall work with this information, although in an anonymised manner are:
- The designated investigating officer.
- The established assessment team, in the event of intervention in case of Psychosocial risk
- The legal consultant, only if legal measures must be taken
- The Data Protection Officer.
10. In addition to this internal channel, you may also use external information channels, when they have been set up, before the competent authorities, in this case, the Independent Authority for Protection of the Reporting Person and, if applicable, before the institutions, bodies or organisms of the European Union that are competent in each case.
11. As regards calculation of the deadlines set out in the regulation for processing the information received, the periods when Polymat is closed, according to the applicable calendar (holidays, bank holidays, non-working days in general …) shall not count.
12. If you wish to submit the information through another means of communication other than the web form, we give you the following options:
- In person and verbally to the manager of Polymat’s ethics channel internal information system, or by Post to Tolosa Hiribidea, 76, 20018 Donostia, Gipuzkoa, indicating on the envelope: “For the attention of the Manager of the Ethics Channel Information System”.
- By email to: canaletico@polymat.eu
