Here you can check the frequently questions in the anonymous reporting channel of PAP Tecnos Innovacion.
How can I increase anonymity when reporting?
Some tips to achieve maximum anonymity, in addition to stating that the report is anonymous, are:
Make sure that in the description of the communication you do not include information that could easily identify you. The same applies to documents you attach as potential evidence.
Do not report from a computer connected to the company’s network, including a mobile device connected to the corporate Wi-Fi. Ithikios does not record information, but before reaching our systems, the data must pass through the company’s own control systems such as proxies or firewalls, which may be configured to know what services you connect to.
You may use the open-source TOR browser, which anonymizes your IP address.
How is personal data processed?
In accordance with the provisions of current data protection regulations, PAP Tecnos is responsible for the processing, management, and storage of the personal data of all persons involved in inquiries and reports. Both the company and the external experts hired comply with the necessary technical and organizational measures to guarantee data security and prevent alteration, loss, unauthorized processing, or access.The platform is designed to apply current personal data protection regulations, specifically Article 24 on whistleblowing channels.
I have lost the access key to check the status of my report. What can I do?
Unfortunately, and for security reasons, only the reporter knows their access code and password. If you lose either of them, you will not be able to track the communication. This does not mean that the communication will not continue its course, only that you will not be able to see its progress or provide additional information if the company requests it.
Is anonymity guaranteed in the report?
During the reporting process, you can decide whether to provide your personal details or not. If you choose not to, you will need to track the progress and resolution of the report yourself through the whistleblowing channel. The channel will provide you with a username and password to access the progress of the report. The channel is independent from the company and does not record IP information from where you connect.
Is there a code of ethics where I can review reportable behaviors?
Yes. You can review the code of ethics from here.
What happens if, later, it is proven that the content of a report is false?
The important thing is to act in good faith and to have grounds to believe that the reported facts are true. PAP Tecnos does not expect the reporter to investigate the facts. If the investigation concludes that no violation has occurred, and it is determined that the notifier acted in good faith, they should not fear any type of retaliation.
What types of offenses can I report?
Criminal offenses established in the Spanish Penal Code as well as in regulations of other countries where PAP Tecnos operates, such as: Crimes of discovery and disclosure of secrets, Crimes of discovery and disclosure of business secrets, Fraud crimes, Crime of price manipulation in tenders and public auctions, Crimes related to industrial property, Crimes of corruption in business (including international commercial transactions), Crimes of receiving and laundering money, Crimes of illegal financing of political parties, Crimes against the Public Treasury and Social Security, Crimes of subsidy fraud, Crimes against workers’ rights, Crimes against the rights of foreign citizens, Crimes against natural resources and the environment, Crimes of risk caused by explosives and other agents, Crimes against public health – drug trafficking, Crimes of bribery, Crimes of influence peddling, Crimes committed in the exercise of fundamental rights and public freedoms guaranteed by the Constitution, Crimes of terrorism, Crimes of smuggling.
When will I receive a response to my report or inquiry? What is the resolution timeframe?
The Ethics Committee will communicate acceptance of the report/inquiry within a maximum period of 7 days. The resolution period for inquiries will be a maximum of 90 days, unless the complexity of the case requires a longer period with proper justification.
Where is the platform that manages the channel located?
The whistleblowing channel operates on an external platform, https://ithikios.com . This company receives the reports and automatically sends them to the company for evaluation. Ithikios’ servers are located in data centers within European territory. Your data is encrypted to minimize intrusion risks as much as possible.
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