VERDIAN, B.V. WHISTLEBLOWING CHANNEL
VERDIAN, B.V. has voluntarily implemented a Whistleblowing Channel as a corporate mechanism to facilitate the reporting of potential irregular conduct, malpractice or any other matter that individuals may wish to bring to the attention of the company.
The purpose of the Whistleblowing Channel is to provide a secure, accessible and confidential means for employees, collaborators, suppliers and third parties connected to the company to report any concerns relating to the company’s operations or environment.
This channel does not constitute a mandatory internal reporting system under Law 2/2023, of 20 February, but rather an internal improvement tool promoted by VERDIAN, B.V. as part of its commitment to ethics, transparency and the principles of good corporate governance.
RIGHTS OF THE WHISTLEBLOWER AND PROCEDURAL SAFEGUARDS
The VERDIAN, B.V. Whistleblowing Channel is a voluntary mechanism that may be used, in good faith, to report any irregular conduct, internal breach or malpractice that may affect the company or its professional environment.
VERDIAN, B.V. is committed to implementing a series of guarantees to protect whistleblowers and ensure the proper management of received communications:
Right to confidentiality and anonymity
- Whistleblowers may choose to submit their reports either anonymously or with identification.
- In any case, the company will handle the information with the utmost confidentiality. Access to the communications will be strictly limited to those individuals expressly authorised to receive, analyse and manage such reports.
Protection against retaliation
- VERDIAN, B.V. guarantees that no retaliatory or adverse action shall be taken against those who, acting in good faith, use the Whistleblowing Channel to report facts or situations they believe to be irregular, even if such facts are ultimately not substantiated.
Responsible use — Reports made in bad faith
- Whistleblowing Channel must be used responsibly and in good faith. The use of the channel to make false, malicious or intentionally harmful allegations will not be tolerated.
- Where, following analysis, a report is found to contain manifestly false information submitted in bad faith or through abuse of rights, the company may close the case and, where appropriate, take the corresponding legal action against the author.
Exclusions from the channel
- The Whistleblowing Channel is not intended for matters involving classified information, legally protected professional secrets, or subjects that are subject to specific legal procedures.
- It is also not the appropriate channel for personal claims of a labour, commercial or contractual nature, which must be addressed through the mechanisms provided by the company.
PROCESSING OF REPORTS
- VERDIAN, B.V. shall acknowledge receipt of communications within a maximum period of 7 days, where possible (except in cases of anonymous reports where no contact information has been provided).
- The company shall endeavour to resolve the matter or inform of the processing status within a maximum of 3 months from receipt of the report, unless the nature of the case requires a longer period, which shall be duly justified.
- Reports will be assessed objectively and with respect for the rights of all parties involved.
- Where irregular conduct is substantiated, VERDIAN, B.V. shall adopt the appropriate measures.
- In the case of anonymous reports, whistleblowers may follow up by accessing the channel using the case ID provided by the tool, allowing for continued communication, additional information, or receipt of responses.
RIGHTS OF THE REPORTED PERSON AND PROCEDURAL SAFEGUARDS
VERDIAN, B.V. ensures that the handling of communications received through the Whistleblowing Channel respects not only the rights of the whistleblower but also those of any person potentially affected by the report.
Accordingly, the company undertakes to guarantee the following principles throughout the process:
Right to the presumption of innocence
- Any individual mentioned in a report shall be treated with respect for their right to the presumption of innocence.
- No disciplinary or rights-limiting measures shall be imposed unless the veracity and seriousness of the reported facts have been established through proper investigation.
Right to information and to be heard
- The person concerned shall be informed of the allegations made against them, at such time and in such manner as deemed appropriate to preserve the integrity of the assessment process.
- They shall be granted the opportunity to provide their version of events and to submit any arguments or evidence they deem appropriate.
Right to confidentiality
- The personal data of affected individuals shall be handled with the strictest confidentiality, and access shall be limited to those authorised to manage the report.
- Every effort will be made to avoid undue harm to the reputation and honour of those involved.
Right to an impartial investigation
- The company will ensure that the investigation is conducted in an objective, impartial manner, based on verifiable data.
- A balance will be maintained between the need to protect the company, the legitimate interest in clarifying the facts, and the rights of all individuals involved.
PROTECTION OF PERSONAL DATA
Any personal data collected through the Whistleblowing Channel will be processed in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), solely for the purpose of managing and investigating received reports.
The following principles will apply:
- Data minimisation: only strictly necessary data will be processed. Irrelevant data will be deleted.
- Confidentiality: access shall be limited to authorised personnel and, where necessary, competent authorities.
- Retention: data will be retained only for as long as necessary to process and resolve the report. It will then be deleted, unless there is a legal obligation to retain it.
- Rights: data subjects may exercise their rights of access, rectification, erasure, restriction, objection, and complaint before the Spanish Data Protection Authority at any time.
For further information or to exercise your rights, please contact: grievances@verdianpower.com.
ACCESS TO THE WHISTLEBLOWING CHANNEL
The internal reporting system (Whistleblowing Channel) is available on the corporate website verdianpower.com under the section “Share Your Opinion”.
The channel is operated through the IT tool Whistle-Bit, provided by the supplier Infodenuncias, S.L. www.infodenuncias.com.
Internal Reporting System Controller (Whistleblowing Channel):
The Internal Reporting System Controller is Verdian, B.V. (grievances@verdianpower.com)
