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INTERNAL INFORMATION SYSTEM
In compliance with Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption (hereinafter, "Law 2/2023"), WEELKO BARCELONA SL (hereinafter, “WEELKO” or “the company”) hereby declares that it has an Internal Information System, with the company being the data controller in accordance with current legislation in this area.
With the aim of strengthening WEELKO’s culture of information and integrity infrastructures, and of promoting a culture of communication as a mechanism to prevent activities or omissions that may constitute infringements under European Union law, serious or very serious criminal or administrative offenses, as well as labor violations related to health and safety at work, WEELKO has appointed a person as the Responsible for the Company’s Internal Information System (hereinafter, “System Officer” or RSIIF).
To this end, WEELKO has appointed the person responsible for Operations and Human Resources as the RSIIF.
Reports of violations related to the aforementioned areas may be submitted through any of the following whistleblowing channels:
By email to the following address: canaletic@weelko.com
By postal mail to the following address: Camí de la Garreta, 92 (Pol. Ind. La Valldan), Berga – addressed to the RCP/RSIIF.
By written notice delivered directly to the System Officer.
The whistleblower may also request an in-person meeting with the System Officer within a maximum period of seven days. Verbal reports made during in-person meetings must be documented in one of the following ways, subject to the whistleblower’s prior consent:
a) By recording the conversation in a secure, durable, and accessible format. In this case, the whistleblower will be informed that the communication will be recorded and will be informed about the processing of their data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016 (General Data Protection Regulation or GDPR).
b) By means of a full and accurate transcription of the conversation made by the person responsible for its handling. Without prejudice to the rights provided under data protection regulations, the whistleblower will be offered the opportunity to review, rectify, and sign the transcription.
WEELKO’s Internal Information System complies with the requirements set forth in Article 5.2 of Law 2/2023, namely:
a) It allows individuals to whom Law 2/2023 applies to report information, through various means, regarding the violations specified in Article 2.
b) It is managed securely, ensuring that reports can be handled effectively within the company, maintaining confidentiality of the whistleblower’s identity and any third parties mentioned in the communication, and of the actions carried out during the management and processing of the report, while also ensuring data protection and preventing access by unauthorized personnel.
c) It includes a Protocol for the Internal Information System, the use of the Internal Reporting Channel, and the role of the System Officer, which establishes guarantees for the protection of whistleblowers, essentially:
Acknowledgement of receipt within seven calendar days of receiving the report.
A maximum ordinary period of three months to respond to the investigation proceedings, in accordance with Article 9 of the Law, maintaining and diligently storing a Register of Reports.
Ability to maintain communication with the whistleblower.
Right of the affected person to be informed of the actions or omissions attributed to them and to be heard.
Guarantee of confidentiality when reports are submitted through unofficial channels or to unauthorized personnel, along with the obligation of the recipient to forward the report immediately to the System Officers.
Respect for the presumption of innocence and the honor of the persons involved.
Compliance with data protection provisions (Title VI, Law 2/2023).
Commitment to immediately forward the information to the Public Prosecutor’s Office if the facts could potentially constitute a criminal offense.
II. PROCESSING OF PERSONAL DATA
WEELKO will process the personal data included in reports received under the protection of Law 2/2023, acting as the data controller, for the purpose of managing them and initiating, where appropriate, the corresponding investigation and adopting corrective measures as necessary. The legal basis for the processing is compliance with obligations imposed by Law 2/2023.
If the report contains special categories of data, such data will only be processed when strictly necessary for adopting corrective measures and/or initiating the relevant investigation and/or conducting applicable disciplinary or criminal proceedings, in accordance with current legislation. In such cases, the legal basis will be the essential public interest.
The processing of personal data will be strictly necessary, as the objectives and obligations of Law 2/2023 cannot be fulfilled without it. Likewise, it is noted that such personal data may only be accessed by authorized personnel when necessary to investigate breaches of company policies, EU law, serious or very serious criminal or administrative offenses, or labor violations related to health and safety at work, to adopt corrective measures, or to carry out disciplinary or criminal proceedings, as applicable.
Personal data may also be disclosed to third parties when there is a legal obligation to do so, including judicial authorities, the Public Prosecutor’s Office, or competent administrative authorities involved in the investigation.
Data will be retained only for the time necessary to determine whether an investigation into the reported facts should be initiated. If corrective measures are deemed appropriate, the data will be kept for the duration of these measures. If disciplinary or criminal proceedings are initiated, data will be retained for the duration of those proceedings.
If no decision is made within three months regarding the initiation of an investigation, the personal data included in the report will be deleted, except for data that must be retained in a blocked state to maintain evidence of the system’s operation, in accordance with Law 2/2023.
Additionally, data revealing conduct not covered by the Law will be deleted, as well as data that are deemed false, unless the falsehood could constitute a criminal offense, in which case the information will be retained for the duration of the legal proceedings.
Finally, it is stated that at any time, the whistleblower may request access to their personal data, rectification or deletion, restriction of processing, objection to processing, and data portability by sending a written request to the postal address: Camí de Garreta, 92 (Pol. Ind. La Valldan), Berga (08600), or by email to: info@weelko.com.
If dissatisfied with the processing of their data, individuals may lodge a complaint with the Spanish Data Protection Agency (AEPD), the competent supervisory authority, located at C/ Jorge Juan, 6 (28001) Madrid (www.aepd.es).
NO RETALIATION
WEELKO explicitly commits not to take any retaliatory actions, including threats or attempts of retaliation, against persons who submit a report in accordance with the provisions of Law 2/2023. Protection measures will be applied during the handling of the case, with respect to those affected by a possible report.
(*) The Internal Reporting Channel allows for anonymous communications.
(**) Although use of the internal channel is preferred whenever possible, depending on the nature, circumstances, and severity of the information, reports may also be submitted to the Independent Authority for the Protection of Whistleblowers, regional authorities or bodies, the Public Prosecutor’s Office, the European Public Prosecutor’s Office, or the competent authority, as appropriate.