WHAT IS THE INTERNAL INFORMATION SYSTEM?
It is the system implemented by IKERLAN for receiving and managing any cases of unsolicited and irregular conduct.
HOW TO REPORT INFORMATION?
We have a safe online platform where you can report your information easily and confidentially. If you wish, you can use a private area for follow-up of the case you have reported and communication with the person managing it.
The Internal Information System (IIS) is the system implemented by IKERLAN for receiving and managing information on any irregularities, ensuring that whistleblowers are protected from retaliation, providing the communication is made within the established legal framework.
The benchmark standard is the Whistleblowing Directive (EU Directive 1937/2019), transposed into Spanish legislation by Law 2/2023 on the protection of persons who report regulatory breaches and to combat corruption
The internal channels made available for this purpose can be used by anyone who has a professional or employment relationship with our company, to notify us of possible criminal offences, administrative offences (serious or very serious) or any breaches of IKERLAN’s code of ethics, with the utmost guarantee of safety and confidentiality and preventing potential retaliation, providing the whistleblower has acted in good faith.
When you access our internal channel platform you will be directed to a homepage showing a reminder of the general aspects of the channel and with detailed information to read on our privacy policies for whistleblowers and affected parties.
From here, you can access a form on which you can provide the details of your information, either in writing or via a secure audio recording, attaching additional documentation if you wish. We use technical measures to protect your identity, deleting the metadata from the files, using voice distortion technology and encrypting all information exchanges.
You may report the information anonymously or provide your identity. Your personal data will be used solely and exclusively used for the purposes specified, which may be consulted in the privacy policy. It will be processed by authorised staff and under no circumstances will your identity be disclosed to the person mentioned in the communication or to any third parties.
On the form, you will be able to request an in-person appointment to explain or expand on the information with the person managing your case. You will be given an appointment within a maximum of 7 days after your request via the private follow-up area on the website, which is explained below.
The verbal communications made must be documented, with the whistleblower’s consent, via a recording in a secure, lasting and accessible format or a full, accurate transcription of the communication. Without prejudice to their rights according to the data protection laws, the whistleblower will be given the opportunity to check, rectify and sign their acceptance of the conversation transcript, wherever possible.
Once the form has been filled in, we will confirm that your communication has been recorded and you will be given a password to access the follow-up area, where you may observe the progress of your case if you wish and communicate and exchange information and documentation with the person managing the report in an easy, secure and confidential manner. It is essential that you store this password properly, as for reasons of confidentiality it cannot be recovered if it is lost or forgotten, in which case you would have to send us the information again.
During the case management process you may be asked for additional information via this follow-up area, and you should therefore access it regularly to check its status. If you wish, when you are given the passwords to access the private follow-up area you will be offered the possibility of receiving an email address for the sole purpose of informing you of any new developments in your case.
The person managing the case will study the information sent to determine whether or not it can be processed, and they will send the whistleblower notification of whether their communication has been admitted for processing.
If your communication is admitted for processing the internal investigation will begin, and you will be notified of the final resolution within a maximum of 3 months (extendable to 6 months if the complexity of the case so requires).
Independent Whistleblower Protection Authority’s external channel:
Although the preferred channel for reporting infringements is the internal channel, if the irregularity you want to report is within the scope of Article 2 of Law 2/2023, i.e. it involves possible criminal offences, serious or very serious administrative offences or breaches of EU law, you may report it via the competent Independent Whistleblower Protection Authority’s external channel, either directly or after having reported the information through our own internal channel.