Whistleblowing Channel Usage Policy
The following legal considerations are provided below to facilitate the use of the Whistleblower Channel by the parties involved.
1. Prohibition of Retaliation and Proper Use of the Whistleblower Channel
Whistleblowers who in good faith report alleged misconduct within the scope of the Whistleblower Channel will be protected from any form of retaliation, discrimination, and penalties because of their reports.
The prohibition of retaliation mentioned above shall not prevent the implementation of appropriate disciplinary measures when an internal investigation determines that the report is false and the person making the report is aware of its falsity. Furthermore, in accordance with the provisions of articles 456 and following of the Penal Code, making false accusations, filing false reports, and simulating crimes are considered punishable offenses with a potential prison sentence of up to two years.
2. Confidentiality of the Whistleblower and the Content of the Report
The utmost confidentiality regarding the identity of the whistleblower is guaranteed. To ensure such confidentiality, it is expressly stated that the access granted to the accused party does not, under any circumstances, include access to data concerning the whistleblower’s identity. All individuals who become aware of reports submitted through the Whistleblower Channel are obligated to maintain strict professional secrecy regarding the whistleblower’s identity and the content of the report. In this regard, the content of the report shall also be treated as confidential, and therefore, it shall not result in any form of admonishment or retaliation if the report is made responsibly, based on objective criteria, and not driven by feelings of revenge, annoyance, or disturbance.
Reig Jofre will ensure that all necessary technical and organizational measures are taken to preserve the security of the collected data in order to protect them from unauthorized disclosure or access.
For this purpose, Reig Jofre has implemented appropriate measures to guarantee the confidentiality of all data and will ensure that identity-related data is not disclosed to the accused party during the investigation, while always respecting the fundamental rights of the individuals involved, without prejudice to any actions that may be taken by judicial authorities.
3. Protection of Personal Data
The personal data collected within the framework of the Whistleblower Channel will be processed solely for the purpose of handling reports and, if necessary, investigating the reported incidents, thereby complying with the legal requirements established in the Organic Law 3/2018 of December 5, on the Protection of Personal Data and Guarantee of Digital Rights.
The data collected in the context of a report that leads to the initiation of an investigation will be included in the “Whistleblower Channel” file, duly registered with the Spanish Data Protection Agency. The responsible party for this file is LABORATORIO Reig Jofre, S.A., with Tax ID number A-96184882 and registered address at Calle Gran Capità, 10, 08970 Sant Joan Despí, Barcelona.
However, it is explicitly stated that the data contained in reports that are not admitted for processing will not be included in any file and will be immediately deleted.
Individuals have the right to exercise their rights of access, rectification, cancellation, and objection by contacting the designated email address, accompanied by a copy of their ID card. However, the right of access for the accused party will be limited to their own personal data and will not include access to data regarding the identity of the whistleblower, given the confidential nature of the Whistleblower Channel.