LOGICALIS SPAIN SLU Whistleblowing Channel

Start

Step 1/5 Categorize concern

To facilitate the further handling of your submission, please help us to categorise it as best as possible.

In which category does your submission best fit?

Any other conduct that violates or encourages other employees to violate the Code of Conduct and the Policies established by the Logicalis Group.

Competition

Consumer protection

Corporation tax

Corruption, conflicts of interest, bribery

Environmental Protection

Financial interests of the Union (expenses, income collection and funds)

Food safety

Harassment, intimidation and discrimination

Prevention of money laundering

Product safety

Protection against radiation and nuclear safety

Protection of personal data and privacy

Public health

Public procurement

Security of networks and information systems

Transportation security

Others

Do you suspect any of the following people?

Compliance, Quality and Sustainability Manager

Data Protection Officer

Director of Legal Services

HR Director

Logicalis Group Chief Legal and Risk Officer

Occupational Risk Prevention Manager

I am not aware of any involvement of these persons

I have read the Terms of use and agree to them in accordance with the notice.

Information

Step 2/5 Personal information

If you prefer not to give your personal details, you can do so by indicating that you want the report to be anonymous.

What is your relationship with the company being reported?

Do you wish to report anonymously?

Yes

This channel requires the whistleblower's identification data are mandatory.

The selected category requires the identification data to be mandatory

First name

Last name

Contact telephone number

This channel is confidential. Your personal data will not be shared. If someone from the organisation needs to know your data, they will request it through the channel and they will only be able to see it if you authorise it.

Details

Step 3/5 Detailed information

Describe in as much detail as possible the event you wish to report, giving as much information and attaching evidence, if available.

Indicate which person or persons are the subject of the report

First and last name

Position

Have you discussed this with any member of management?

Yes

I do not remember

Are there any witnesses? Please indicate their names.

First and last name

Position

Tell us what you want to report in detail

Would you like to attach any additional documents?

Image (png, jpg, gif), Audio (wav, mp3), Video (ogg, mp4, mov, avi, wmv, mpg, mpeg) or PDF document up to 20Mb. Attention! If you report anonymously, make sure that the attachments do not include information in the content or metadata that could identify you.

Confirm

Step 4/5 Confirmation

As the last step of the process, you must indicate a password that only you will know. This password, together with the identification code that we will give you at the end of the process, will be the only way to follow the progress of your communication.
PLEASE KEEP YOUR PASSWORD SAFE, AS IF YOU LOSE OR FORGET IT, YOU WILL NOT BE ABLE TO FOLLOW UP YOUR COMPLAINT.

Password

Password confirmation

Finish

Step 5/5 Finalize

You have now entered all the information required to start the whistleblowing process.

The people or facts reported will be investigated and appropriate action will be taken.

The whistleblower is responsible for the accuracy of the information provided in this complaint. Otherwise, the company reserves the right to take legal action against the whistleblower.

This is the last form in the process. When you click on Send, the investigation will begin and the resolution of your claim will be shown on the platform within a maximum period of 3 months

I have read and understand the information on the processing of my personal data in accordance with the provisions of the Privacy Policy .

Terms of Use

1- IDENTIFICATION DATA

In compliance with the duty of information established in Law 34/2002, of July 11, 2002, on Information Society Services and Electronic Commerce (hereinafter, "LSSI"), the following information is provided below: the owner of https://logicalisspain.sistemadenuncias.com (hereinafter, the "Web Site") is LOGICALIS SPAIN, S.L.U with TAX number B82832155, company domiciled in Avd. Diagonal 569 2ªplta 3ºpta edificio L'Illa Diagonal, 08029-Barcelona, entity registered in the Commercial Registry of Barcelona Page B-266359 Volume 47836 Sheet 121 Inscription 79 (hereinafter, LOGICALIS)

Contact details:

Telephone: +34 93 363 25 90

E-mail: [email protected]

2- OBJECT

These are the Conditions (hereinafter "General Conditions") that regulate the access, navigation, use of the Web Site, and the responsibilities derived from the use of the same.

This Web Site may only be used to send communications on actions or omissions that may involve an illegal act or contrary to current regulations or contravene the principles and values of the Code of Ethics of LOGICALIS, “Logicalis Code of Conduct Policy” (hereinafter Code of Conduct), the “Anti-Bribery Policy” (hereinafter the Policies) and the “Procedure for Handling Allegations Conducting Investigations” (hereinafter the Procedures).

3- USERS AND THEIR RESPONSIBILITY

By using the services of the Website, the user accepts the present General Conditions, which define the rights and obligations of the LOGICALIS Website. Any person accessing this website assumes the condition of User, undertaking not to use the Website or the information contained therein for activities contrary to the Law, morality or public order and, in general, to use it in accordance with the General Conditions established by LOGICALIS.

The User assumes responsibility for the use of the Website in a legitimate manner and in accordance with these Conditions. By way of example and not limitation, the User is responsible for:

Use the Website in accordance with the Object described in these General Conditions.
Providing all the information requested through the Web Site's complaint form. The Website allows communication in an anonymous way, so the User must review the information provided in case he/she wishes to preserve his/her identity completely.
The User may choose to send a communication providing contact and identification data or not to provide them. In both cases, the Website will provide the User with a unique identification number and a password that will allow him/her: (i) to know at all times the status of the communication made; (ii) to download a certificate containing all the information communicated and the result of the investigation. It is important for the User to record such information in a safe place. For security reasons, if this information is lost, the User will not be able to recover it. LOGICALIS is not responsible for the loss of such information.
Not to make use of the Website in bad faith and to provide truthful information to the best of its knowledge and belief. If the entity ascertains that the User has submitted the complaint in bad faith and/or with knowingly false information or documentation, it reserves the right to take legal action if the complainant has been identified.

The User shall be liable for any damage or prejudice of any kind that LOGICALIS may suffer, directly or indirectly, as a result of an improper use of the Website, a breach of these Conditions or a breach of the law in force.

Likewise, the User will not be able to hold LOGICALIS responsible for any damages that may arise from such activities beyond his control and of which he is effectively unaware.

4- RESPONSABILITY OF LOGICALIS

The entity shall not be liable for possible errors in accessing the Website or its contents and/or services, but will do its best to ensure that they do not occur.

The entity reserves the right, without prior notice, to temporarily suspend access to the Website in the event that maintenance, repair or improvement work is required. In this case, specific Channels will be enabled so that the User can communicate through them, any irregularity that he/she has detected within the entity or of which he/she suspects.

5- EXCLUSION OF GUARANTEES AND LIABILITY

The entity is not responsible, in any case, for damages of any nature that may be caused by Users, including but not limited to: errors or omissions in the contents and / or lack of availability of the portal or the transmission of viruses or malicious or harmful programs in the contents, despite having taken all the necessary technological measures to prevent it.

6- INTELLECTUAL AND INDUSTRIAL PROPERTY

All contents of the Web Site (including, but not limited to, databases, images, drawings, graphics, text files, audio, video and software) are the property of the entity and are protected by national and international intellectual and industrial property laws, and all rights are reserved.

The domain name, trademarks, labels, distinctive signs or logos appearing on the Web Site are the property of the entity. The texts, graphic drawings, videos or audio supports that can be found in this Web Site, now or in the future, are property of the entity, so it is not allowed its:

Reproduction, distribution or modification, unless authorized by the entity or it is legally permitted.
Any infringement of the rights of the entity or of the legitimate owners of the same.
Use for any commercial or advertising purposes other than those strictly permitted.
Any attempt to obtain the contents of the Website by any means other than those provided to Users, and those normally used on the Website.

LOGICALIS does not grant any license or authorization of use of any kind on its intellectual and industrial property rights or on any other property or right related to the Website, and in no case shall it be understood that access and browsing by Users implies a waiver, transmission, license or total or partial transfer of such rights by LOGICALIS.

Any use of such contents not previously authorized by LOGICALIS shall be considered a serious breach of intellectual or industrial property rights and shall give rise to the legally established liabilities.

7.- PROTECTION OF PERSONAL DATA

LOGICALIS treats the data of users, always in compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation or GDPR) and the Organic Law 3/2018 of 5 December on the Protection of Personal Data and guarantee of digital rights (LOPDGDDD).

For more information on the processing of data of users of the Channel, you can consult the Privacy Policy.

8- VALIDITY OF THE TERMS OF USE

The entity may modify at any time the conditions set forth herein. The validity of these conditions will depend on their exposure and will be in force until they are modified by others duly published.

9- MODIFICATIONS

The entity reserves the right to make unannounced changes it deems appropriate in its Web Site, and may change, delete or add content provided through it, as well as the way in which they are presented or located on its Web Site.

10.- SAFEGUARD CLAUSE

All the clauses or extremes of these conditions of use must be interpreted in an independent and autonomous way, not being affected the rest of the stipulations in case one of them has been declared null and void by judicial sentence or firm arbitration resolution. The affected clause or clauses shall be replaced by another or others that preserve the effects pursued by the present General Conditions.

11- APPLICABLE LAW AND JURISDICTION

The relationship between the entity and the User shall be governed by current Spanish law and any dispute shall be submitted to the competent Courts and Tribunals.

Data protection and consent to LOGICALIS SPAIN SLU

1. DATA CONTROLLER

This Whistleblower Channel is the responsibility of LOGICALIS SPAIN, S.L.U, with TAX number B82832155, company domiciled at Avd. Diagonal 569 2ªplta 3ºpta edificio L'Illa Diagonal, 08029-Barcelona, entity registered in the Commercial Registry of Barcelona at page B-266359, volume 47836, sheet 121, inscription 79 (hereinafter, LOGICALIS).

We inform you that LOGICALIS has designated a Data Protection Delegate who can be contacted at the following e-mail address [email protected] .

You can consult LOGICALIS SPAIN's general Privacy Policy by clicking on the following link: https://www.es.logicalis.com/es/politica-de-privacidad

2. MOTIVATION

LOGICALIS makes this Whistleblower Channel available to its stakeholders in compliance with the recent Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption (hereinafter, " Whistleblower Protection Law ").

In addition, LOGICALIS fully complies with the current regulations on the protection of personal data; specifically, with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter, " GDPR ") and Organic Law 3/2018 of 5 December on data protection and guarantee of digital rights (hereinafter, " LOPD ").

3. PERSONAL DATA PROCESSED

As indicated in the previous section, LOGICALIS's Whistleblower Channel allows the submission of anonymous complaints.

However, if the informant wishes to submit the complaint in a nominative way, LOGICALIS may collect, within the framework of a communication, the following types of data from the informant and, where appropriate, from the persons involved in the communication:

Identifying data: Name and surname(s).
Contact data: Telephone and e-mail.
Professional data: Professional position.

Additionally, LOGICALIS may process other types of data by virtue of the allegedly criminal or irregular facts reported and the supporting documentation that may be appropriate to investigate the reported conduct.

No personal data shall be collected if it is not clearly relevant to the processing of specific information. In the event that irrelevant data is accidentally collected, such data shall be deleted from the Whistleblower Channel without undue delay.

If it is proven that the information provided or part of it is not truthful, it will be deleted immediately as soon as this circumstance becomes known. In the event that this lack of truthfulness may constitute a criminal offense, the information will be kept for the necessary time during the legal proceedings.

4. PURPOSES OF DATA PROCESSING

LOGICALIS shall process the data to which it may have access as a result of the communications received for the following purposes:

Receiving and deciding on the admission for processing of communications received through the Complaints Channel.
Once the communications have been admitted for processing, to carry out the investigation of the reported facts and to adopt, if appropriate, the pertinent corrective measures.
Keeping the complainant informed about the admission, or not, of his communication as well as the progress and results of the investigation process in the event that there are sufficient grounds to admit his communication for processing.

5. LEGITIMACY FOR DATA PROCESSING

LOGICALIS has the following legitimate bases for the processing of the data, taking into account the conduct reported through this Whistleblower Channel:

Compliance with legal obligations applicable to LOGICALIS if the communication refers to breaches provided for in the Whistleblower Protection Act:

o Non-compliance with European Union law,

o Commission of crimes or serious or very serious administrative offenses or any violations of the regulations for the prevention of money laundering;

Legitimate interest of LOGICALIS in ensuring that corporate behaviors are respected, without the processing of data in this framework entailing an imbalance to the rights of the data subjects and without the processing being likely to cause them prejudice, if the communication concerns conduct contrary to LOGICALIS's Code of Ethics or Code of Conduct.
Public interest of LOGICALIS when the Whistleblower Channel is not mandatory or the processing is carried out in the scope of public disclosure.

6. RECIPIENTS OF THE INFORMATION

The data to which LOGICALIS may have access due to the communications received through the Whistleblower Channel, may be communicated to:

Public bodies or institutions, judges and courts when necessary for the adoption of disciplinary measures, for the processing of legal proceedings that, where appropriate, or in those cases in which it was legally required.
To the Public Prosecutor's Office, when the procedure is within its competence.
When necessary for the investigation or the adoption of disciplinary or corrective measures to the LOGICALIS Group entity where the reported facts have occurred.

Regarding the communication of the informant's personal data, LOGICALIS will guarantee that his identity, and all those personal data that LOGICALIS may have about his person, will be in any case reserved and that they will not be communicated to the persons to whom the reported facts refer nor to third parties, respecting in any case the fundamental rights of the person, without prejudice to the actions that, if necessary, may be taken by the competent judicial authorities .

7. TIME LIMITS FOR THE STORAGE OF DATA

The personal data to which LOGICALIS may have had access as a result of the communications received through the Complaints Channel, will be processed for the time necessary to decide on the appropriateness of initiating an investigation into the facts reported and for the management of the communication provided that it is admitted for processing.

Specifically, LOGICALIS will process the personal data within a maximum period of three months from receipt of the communication, except in cases of particular complexity, in which case it could be extended for an additional three months.

Once the aforementioned period has elapsed without any investigation actions having been initiated, the data will be deleted from the communication system, except for the purpose of maintaining evidence of the operation of the system and in an anonymized form.

In the case of communications that have not been sent, they will be kept in an anonymized form, completely eliminating the personal data.

8. USER RIGHTS

The regulations for the protection of the informant guarantee Users the following rights recognized in the data protection regulations, which may be exercised whenever applicable:

Access : Allows interested parties to know what information is held, where it has been obtained, to whom it has been provided and for what purposes it has been processed.
Rectification : Allows interested parties to rectify any erroneous or outdated data.
Deletion : Allows interested parties to stop the processing of their data.
Opposition : Allows interested parties to stop the use of their data for a specific purpose. In the case of the person to whom the facts related in the communication refer, it will be presumed that, unless proven otherwise, there are compelling legitimate reasons that legitimize the processing of their personal data.
Limitation : Allows data subjects to restrict the processing of their data, but in such a way that they are retained for some subsequent purpose.
Portability : Allows data subjects to obtain a copy of their data in electronic format and, under certain circumstances, to request that it be communicated to another service provider. It is only applicable for computerized processing carried out with the User's consent or for the fulfillment of a contract.
Revocation of consent : Allows interested parties to withdraw the consent, if any, given for the processing of their data.

However, the exercise of these rights is limited to those whistleblowers who have identified themselves at the time of submitting the communication. If LOGICALIS has reasonable doubts about the identity of the informant requesting the right, he/she may request information that allows him/her to prove his/her identity.

Additionally, users of the Channel are informed that some of the rights indicated in the previous points may be limited in accordance with the provisions of the Whistleblower Protection Law. Specifically, the rights of access and opposition may be limited in the following terms when they are exercised by the person under investigation:

When the investigated person exercises the right of access, the law limits the knowledge of the informant's personal data that will not be part, in principle, of that right of access as it is data of a third party.
If the data subject exercises the right of opposition, it will be understood that there are compelling legitimate grounds that legitimize the continued processing of the data, in accordance with Article 21.1 of the GDPR.

Whenever applicable, they may exercise the aforementioned rights before LOGICALIS by mail to the above address or by e-mail to [email protected]

If the informants wish further information in this regard or consider that their right to data protection has been violated, they may contact the Spanish Data Protection Agency (www.aepd.es) or the Data Protection Delegate of LOGICALIS [email protected]

9. SECURITY MEASURES

In compliance with the aforementioned current regulations, LOGICALIS has incorporated the appropriate technical and organizational measures to guarantee the protection of the rights and freedoms of those affected by the processing of their personal data, including the corresponding data security measures, reinforced, among other aspects, with respect to the necessary confidentiality and, singularly, the disclosure of the identity of the informant, data protection and secrecy of communications, in order to prevent the loss, misuse, alteration, unauthorized access and theft of the data provided by the informant.

10. ACCURATE AND TRUTHFUL INFORMATION

LOGICALIS informs the complainant that the communication transferred through the Whistleblower Channel may lead to the initiation of internal or external investigations and may have negative consequences for those affected.

For this reason, you should only provide us with information that is believed to be correct, to the best of your knowledge and belief, and that is relevant to detect a breach of LOGICALIS's regulatory compliance and/or Code of Ethics or Code of Conduct.

LOGICALIS may initiate any disciplinary and/or legal action it deems appropriate whenever the communication is manifestly unfounded or there are, in the opinion of LOGICALIS reasonable indications that the information has been obtained through the commission of a crime.