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/1. Introduction
The das-Nano Group is committed to promoting a robust integrity infrastructure and fostering a culture of information as a mechanism to prevent and detect threats of public interest. As a result of this commitment, the Board of Directors of the group’s parent company, das-Nano, S.L., has agreed to design, implement, maintain, and improve a Whistleblowing Channel in accordance with the provisions of Law 2/2023 of February 20, regulating the protection of individuals reporting regulatory violations and combating corruption (hereinafter referred to as “the Law”).
The purpose is to provide adequate protection to whistleblowers and strengthen the culture of information within the das-Nano Group. In guarantee of the diligent management of the system, the Board of Directors has appointed a Responsible Body for the Whistleblowing Channel as the entity in charge, which will carry out its functions independently and autonomously from the other bodies of the das-Nano Group. The Responsible Body must ensure the correct direction of the principles that are part of this policy.
The entire organization assumes and shares this Internal Whistleblowing Channel policy, demonstrating motivation, commitment, and individual responsibility. The das-Nano Group is committed to adhering to the principles of the system and to require all its employees and, to the extent possible, its collaborators, to uphold this commitment.
/2. General Principles of the System
The Whistleblowing Channel is governed by the following principles:
Accessibility: The das-Nano Group has an Whistleblowing Channel that allows individuals covered by the Whistleblower Protection Law to report violations specified in that legislation in a work or professional context, in writing, verbally, or in both ways. Information about the channels of information will be clear and easily accessible and usable for individuals who want to report a violation. Additionally, the operation of the information channels will be public.
Confidentiality: Communications through the designated information channel can be made anonymously, and at all times, the reporting channel will be confidential and have technical security guarantees. If the whistleblower decides to make the communication without remaining anonymous, their identity will be treated as confidential information. The treatment of this information will be limited to a small group of individuals so that the whistleblower’s identity and that of affected third parties cannot be disclosed except in cases expressly provided for in the applicable regulations. Necessary technical and organizational measures must be employed to ensure that communications and investigations managed in the system are treated securely, confidentially, and in compliance with personal data protection regulations.
Efficiency: Communications made through the Whistleblowing Channel and the designated channel will be processed with the utmost speed and diligence, always respecting the deadlines established in the Whistleblower Protection Law and any other applicable regulations. As a general rule, acknowledgment of receipt of the communication should be made within 7 natural days, and the deadline for responding to investigation actions will not exceed 3 months from the communication, unless in cases of greater complexity, in which case the response deadline may be extended to a maximum of 6 months.
Objectivity: Communications received through the Whistleblowing Channel will be treated objectively, and the presumption of innocence of the individuals affected by the reports will be maintained until the end of the investigation. The Body Responsible for the System will strive to avoid any conflict of interest that may arise.
/3. Whistleblower Protection
Individuals who report the possible existence of violations through the das-Nano Group’s Whistleblowing Channel in compliance with the requirements established by Law 2/2023 of February 20, will enjoy protection guarantees against possible reprisals as provided by the regulations.
The Board of Directors of das-Nano, S.L. expressly prohibits the commission of any act constituting reprisals, including threats and attempts at reprisal, arising from the reported communication. Whistleblowers will be protected against acts or omissions prohibited by law, unfavorable treatment, or disadvantages in the workplace due to their status as whistleblowers or for having made the disclosure public.
/4. Publicity
To ensure the proper management and smooth operation of the Whistleblowing Channel, this system’s policy will be appropriately disseminated throughout the organization so that all employees and individuals associated with the das-Nano Group are aware of its principles and can adhere to them. This policy will be reviewed periodically and will be modified when necessary for its continuous improvement, in which case it will be communicated to the interested parties.
