Internal Information System in compliance with Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption and harassment in the workplace.
The principles of our company BLASCO JOYERO SL, are based on an ethical criterion that includes compliance with current legislation and the protection of our staff when, for any reason, they have observed that something is not in accordance with current regulations or that someone has breached them and wish to report it to the highest representatives of the company. For this reason, and in compliance with the Law that is the subject of this section, the company has designated a person responsible for the information system provided for in the aforementioned Law, whose personal details have been disseminated among the company's personnel for the purpose of identification as the person most responsible for the communication channel and for the obligations established in this Law.
By virtue of the legal provisions, the company establishes a preferential channel for any employee to inform the system manager in the event of any breach of a legal rule, in such a way that the company guarantees the confidentiality of the communication, the identity of the informant, as well as the identity, if any, of the person affected by such information, who shall also enjoy his or her right to honour and the presumption of innocence.
The informant can make his or her communication either in writing, in accordance with the model that has been disseminated among the staff, or in a free handwritten letter if he or she so wishes, or even verbally to the system manager.
If the company decides to establish an external channel, it shall disseminate its identity and contact references to staff for the purpose of awareness and identification.
Once the information has been received, the company shall protect the informant by keeping his or her data confidential. Unless there is a risk that confidentiality may be breached, it shall send an acknowledgement of receipt to the informant within seven days of receipt of the communication and within two months it shall reply to the informant on the action taken by the company; this period shall never exceed three months from the acknowledgement of receipt. In the event that, due to the complexity of the matter, the company needs more time, it shall inform the informant, but this shall never exceed three additional months. In any case, the company may ask the informant for additional information.
If the report has not been sent to the system administrator but to another person in the company, the latter is obliged to send such information immediately and with the same obligations as in the preceding paragraphs to the system administrator, since failure to do so would constitute a very serious infringement as stipulated by law. It is the responsibility of the system administrator to decide whether the matter reported goes beyond an administrative matter and, in the event of indications of criminal liability, to inform the Public Prosecutor's Office immediately.
The information received, as well as the informant's details and the actions undertaken by the company, will appear in the information register consisting of a register-book whose custody and safekeeping corresponds to the person responsible for the system in order to guarantee the confidentiality of all the details of said report and its author, and therefore it will not be public. Personal data shall only be kept for the time required to analyse the event that is the object of the information and, under no circumstances, shall it be kept for a period exceeding ten years.
In any case, the whistleblower may choose to turn to the Independent Authority for the Protection of Whistleblowers, a public law body set up by law, or to the competent regional authorities.
Upon receipt of a report of the nature provided for in this Law, a file shall be opened with the date of receipt, the identity of the informant and of the person or persons, if any, affected by the information, an identification code to locate the file in the Register Book, the reason for the report, as well as the actions taken, the measures adopted and, if applicable, the date of closure of the file.
Both the file and the information in the logbook shall be for the exclusive use of the person responsible for the system, as well as, where appropriate, the administrative or judicial authorities involved in the case.
Channel Manager: Fco. Javier González Aragón
(Barítono Marcos Redondo 3. 30005 Murcia)