Internal Information System Policies

The Internal Information System of HELIOPAL S.A. is the channel for communicating, confidentially and effectively, any information about irregular acts committed by HELIOPAL S.A. or its staff, which have been known in the framework of an employment or professional relationship maintained with our organisation by the provisions of Law 2/2023, of February 20.

The organisation has configured the Internal Information System through the following channels:

  • In writing:
  • By post, addressed to the Head of the Internal Information System of the HELIOPAL S.A. organisation at AVENIDA SON CALIU Nº 18, 07181, PALMANOVA (CALVIA), BALEARIC ISLANDS.
  • Verbally:
  • At the informant’s request, the information may also be submitted through a face-to-face meeting with the System Manager within a maximum period of seven days from the submission of the request.

-Apart from these channels, communications can be interposed with the competent authorities’ external information channels.

-Once the complaint has been received, the person in charge of the Internal Information System will communicate the acknowledgement of receipt of the complaint to the complainant within less than seven days -in the case of nominal complaints-. In any case, the complainant will be informed of the rights and obligations established by the regulations to protect personal data.

-The person in charge of the Internal Information System will issue a reasoned report that will consider or dismiss the intervening communication, justifying, in any case, the decision taken. The report shall be notified to the informant and the person concerned no more than three months after the expiration of the period of seven days after the communication is made, except in cases of particular complexity that require an extension of the deadline, in which case, it may be extended to a maximum of another three additional months.

-During the processing of the complaint, communication and contact can be maintained with the informant/complainant and, if considered necessary, to request additional information from the reporting person.

The person affected by the information or complaint will be notified of the facts reported succinctly. In addition, they will be informed of their right to submit written allegations and of the processing of their personal data. However, this information may be provided at the hearing if it is considered that its provision beforehand could facilitate the concealment, destruction or alteration of evidence.

-The person in charge of the Internal Information System/Complaints Channel guarantees confidentiality to all those who use the Internal Information System/Complaints Channel. In addition, confidentiality is guaranteed when the communication is sent through reporting channels other than those established or to staff members not responsible for its treatment.

-During the processing of the file, the persons affected by the communication shall have the right to the presumption of innocence, to the right of defence and the right of access to the file, as well as to the same protection established for the informants, preserving their identity and guaranteeing the confidentiality of the facts and data of the procedure.

-The processing of personal data resulting from the application of this procedure will be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, in Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights, in Organic Law 7/2021, of May 26, on the protection of personal data processed for prevention, detection, investigation and prosecution of criminal offences and the execution of criminal sanctions.

-The person in charge of the Internal Information System/Complaints Channel shall immediately send the information to the Public Prosecutor’s Office when the facts could indicatively constitute a crime or to the European Public Prosecutor’s Office if the points affect the financial interests of the European Union.

-The organisation guarantees the absence of retaliation against anyone who brings to its attention possible illegal conduct, has reported a regulatory breach, collaborates in its investigation, or helps to resolve it.

-Persons who report or disclose violations contained in Art.2 of Law 2/2023, of February 20, and of actions or omissions that may constitute a profound or severe criminal or administrative offence shall have the right to protective measures provided that the conditions set out in article 35 of the regulation above are met. The protective measures are set out in article 38 of Law 2/2023, of 20 February.

-The complaint or information will be kept on the organisation’s premises in accordance with its policy of archiving and preserving documents.

-The organisation has a record of all complaints received. Complaints will be kept only for as long as necessary and proportionate to comply with the requirements imposed by Law 2/2023 of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption and by the provisions of Article 24 and other applicable articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the guarantee of digital rights.

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