Insud Pharma S.L.U. (hereinafter, the “Company”), as a responsible corporate citizen, is committed to conducting its affairs to the highest standards of ethics, integrity and honesty and always in compliance with its Code of Ethics, ABC Book and related policies.
To help deliver on this commitment, we are all encouraged to denounce improper, unethical or illegal conducts within the Company. If you observe or suspect any breach of the Code of Ethics or other corporate policies or if you have complaints concerning other ethical, legal or regulatory matters, you can report this to your supervisor, to Human Resources or to the Legal Team.
If you feel unsure about where to go with this kind of concerns or you feel uncomfortable reporting through normal channels of communication or if you have reported through normal channels with no effective response, you can always access the dIrectLine.
The dIrectLine is a whistleblower established as an alternative communication channel for employees that will put you in direct contact with the Compliance Committee.
The dIrectLine operates 24 hours a day, seven days a week and has been designed to protect our confidentiality. The dIrectLine provides a web-based reporting capability ww.insudpharmadirectline.com, that we can access from any dispositive internet connected and where all reports will be addressed confidentially, independently, seriously and urgently. Also you can use this email address: dIrectLine@insudpharma.com
- The dIrectLine is to be used to communicate potential violations of law, regulation or the Code of Ethics or corporate policies.
- The dIrectLine has to be used in good faith. The Company will protect the person who uses the directLine from any kind of retaliation.
- Retaliation is understood as any “adverse action” such as: firing or laying off, blacklisting, demoting, denying overtime or promotion, disciplining, denial of benefits, failure to hire or rehire, intimidation/harassment, making threats, reassignment affecting prospects for promotion or reducing pay.
- Malicious reporting, or knowingly filing a false report can trigger disciplinary measures.
- When using the dIrectLine, providing your identity through the communication of your personal data is strongly recommended, as otherwise it is more difficult to carry out an investigation given that the Compliance Board cannot make follow-up questions. Moreover it may be very difficult and, in some countries, legally impossible for the Compliance Committee to properly analyze the situation. Furthermore, if you report anonymously, it is not possible for you to be monitored by the Company for potential acts of retaliation and may lead to the undesirable situation that the Compliance Committee focuses its attention on try to find out who has made the communication instead of on the facts communicated.
- All communications with the dIrectLine will be dealt with in the strictest confidentiality. It is recommended as well that you keep your report confidential. The identity of the people who uses the dIrectLine will always remain confidential within the Compliance Committee and a very restricted group of persons designated by it for the management and investigation of the facts related to the communication.
- Reporting trough the dIrectLine you can make sure that your report will directly be received by the Compliance Committee: http://www.insudpharmadirectline.com/lang-es/pag/compliance/?lang=en
- Notwithstanding the above, and as a consequence of the investigation or inquiries undertaken in relation to a report received in the dIrectLine, if the Compliance Committee considers there exists a breach of applicable laws (or is obliged by such applicable laws), the Company reserves the right to provide the authorities with all the information they require, including the identity of the persons involved.
- The Company guarantees that will comply with the applicable data protection legislation within the data processing that could take place when the actions established on this document are carried out.
- In this sense, the Company warrants that the personal data collected and processed through dIrectLine will be only those strictly necessary for the investigations of the facts that have been communicated. In consequence, personal data will be adequate, relevant and not excessive in relation to the purposes for which have been collected that are those established herein.
- According to Spanish Organic Law 3/2018, of 5 December on Personal Data Protection and Guarantee of Digital Rights, personal data provided or created as a result of the use of dIrectLine will be included on a file named “Canal de Denuncias” (Whistleblower Channel) ownership and responsibility of Insud Pharma S.L.U. with address on St. Manuel Pombo Angulo 28, 28050-Madrid (Spain) and will be processed just for the management of the communications carried out through dIrectLine including the investigation of the facts related to the communication as set forth herein..
- You can exercise his access, rectification, deletion or opposition rights by sending a communication to Insud Pharma S.L.U. in the address indicated above or an e-mail to firstname.lastname@example.org providing a copy of your ID or any other documentation accrediting your identity.
- The Compliance Committee will inform those persons whose conduct has been reported as improper about such circumstance, as soon as the situation allows this and always in a maximum deadline of 3 months since the alleged violation was reported. The reported persons will always be able to ask any questions they might have at this time, and present any arguments in their defense that they consider appropriate. Nevertheless, under no circumstances the reported person will have access to the data as regards the reporting person.
- All personal data will be integrally deleted, in accordance with the provisions set forth in Spanish Organic Law 3/2018, of 5 December on Personal Data Protection and Guarantee of Digital Rights,when no longer needed or relevant and, in any case, within 2 months if the violation that was reported was not proven. For the case judicial or administrative actions are initiated by the Company, the data will be deleted once such proceeding has been definitively concluded.
- You can report to the dIrectLine in any language. The Web-based questions appear in English and Spanish but if you need assistance, you can request a translator to be appointed by the Compliance Committee.
- If a violation of the Code of Ethics or corporate policies is proven, Human Resources shall be reported for the corresponding disciplinary measures, according to the formalities required in the corresponding jurisdiction.