SAYMA’s ethical channel.
In accordance with the provisions of Sayma’s Code of Ethics, respect for the law is one of the fundamental principles of our company, which assumes as one of its key objectives to ensure the awareness of the people who are part of and collaborate with Sayma on the importance of minimizing the risks of illegal or unethical practices within the organization. Before communicating through our Ethics Channel, you should be aware that it is a secure and confidential channel, that you can communicate with us anonymously and, in addition, you should be aware of the facts and/or behaviors that you can communicate to us through it, as well as its scope of protection, which are included in the rules of use. Once you have completed the information, it is very likely that we will need to contact you to request clarification or expansion of the facts communicated. If you identify yourself (or if you do not, but leave a contact email), we will do so through the email you indicate, otherwise it will be unlikely that we will be able to ask you for further information.
RULES FOR THE USE OF THE ETHICAL CHANNEL
In accordance with the provisions of Sayma’s Code of Ethics , respect for the law is one of the fundamental principles of our company, which assumes as one of its key objectives to ensure the awareness of the people who are part of and collaborate with Sayma on the importance of minimizing the risks of illegal or unethical practices within the organization. This reporting channel is also available to comply with regulations on the protection of persons reporting breaches of European Union law. It is important to understand that the purpose of these regulations is to protect the whistleblower from possible retaliation in the employment or professional relationship in the context of an infringement committed by Sayma or its employees or managers, in the areas listed below, which may constitute a serious or very serious criminal or administrative offense or affect the general interest. When you use this channel you are assuming that you have read and accepted the rules of use described here and the conditions on data protection that are reflected in this website. It is a secure and absolutely confidential channel, and communications can be made completely anonymously by following the steps described in this document. Before providing any information to this channel it is important to read and accept the following questions:
- This channel is enabled to report any breach of those included in our Code of Ethics and any other information that reflects irregular, illicit or criminal behavior in areas related to:
- Internal and external fraud,
- Discrimination, labor and sexual harassment,
- Acts of corruption and bribery, Money laundering,
- Offenses and infractions against Social Security and the Treasury,
- Infringements of labor law in the area of Occupational Safety and Health.
- Non-compliance with privacy and personal data protection regulations, network and information systems security,
- Any other conduct that implies the commission of a crime or serious or very serious administrative infraction.
- This channel is not authorized for communicating violations of private law rules that regulate relations between individuals and that do not affect the proper functioning of public and private entities, such as service complaints, making claims, spreading rumors, etc.
- The information you provide must be based on good faith, as the law does not protect anyone who provides false information or information obtained illegally.
- The provision of personal data is the full responsibility of the informant, who must comply with the regulations in this regard. The informant is also responsible for the confidentiality and custody of the identification code provided by the company.
- If you wish, you may provide information anonymously; if when making the communication, you identify yourself or provide an address, e-mail or safe place to receive notifications, we will send you an acknowledgement of receipt of the communication within seven calendar days of receipt, unless this could jeopardize the confidentiality of the communication.
In this case, the complainant may create an e-mail account with a fictitious identity (by sending it via a wifi connection that is not his/her own), for example: at Google, as follows:
https://support.google.com/mail/answer/56256?hl=es
The e-mail account created anonymously will be used to contact the complainant to gather more information about the case. Whether you identify yourself or not, we recommend that you provide a way to maintain communication with you or to ask for additional information so that we can process the investigation and inform you of the actions or omissions attributed to you, and so that you can exercise your right to be heard at any time.
- If you do not identify yourself and make an anonymous communication, Sayma will send you an identification code with which you can check the status of your communication. In this case we will contact you via the email address provided, as we do not know who is behind it and we do not have personal access, so you will have to check regularly if you have messages, otherwise the investigation may be limited.
- The complaint will be received by the person in charge of the Internal Information System. Reporting Channel. We will preserve the identity of the informant. This identity will never be subject to the right of access to personal data and may only be communicated to the judicial authority, the Public Prosecutor’s Office or the competent administrative authority, requiring that in any case third parties are prevented from accessing it. The person to whom the facts reported refer shall in no case be informed of the identity of the informant or of the person who, where appropriate, has made the public disclosure.
We will also preserve the information of the persons to whom the facts related in the communication refer, in the event that the information, even with apparent signs of truthfulness, has been manipulated, is false or responds to motivations that cannot be protected by law. In such cases, the sole and exclusive responsibility is that of the informant, who must respond in any case, exempting the entity holding the information, as well as the manager of the internal information system. Access to our internal information system is limited to the person responsible for the system. They will work with this information, but in an anonymized form:
- The assigned instructor.
- The assessment team defined, in the event of a psychosocial risk scenario
- To the legal services person consulted, only if legal action is to be taken.
- To the person in charge of data protection.
- In any case, we will respect the presumption of innocence, the right to be heard and the honor of the persons under investigation. In the event that we open an investigation, the maximum duration of the same may not exceed three months from the receipt of the communication, except: cases of special complexity that require an extension of the term, in which case, this may be extended up to a maximum of three additional months or specific cases that have legally established other deadlines.
- In addition to this internal channel, you can also use, when created, external reporting channels to the competent authorities, in this case, the Independent Authority for Whistleblower Protection and, where appropriate, to the institutions, bodies or agencies of the European Union that are competent in each case.
- For the purpose of calculating the deadlines foreseen in the regulations for the management of the information received, Sayma’s closing periods will not be counted, in accordance with the calendar applicable to Sayma (vacations, holidays, non-business days in general, etc.).
- If you wish to send us the information through another means of communication other than the web form, we present you the following options:
- By e-mail to: canal_etico@sayma.es
- By mail to the address:
Avenida de la Libertad 10, 6ª Planta 20004 Donostia, Spain
indicating on the envelope: “Ethical Channel”.
