ethical channel

Welcome to the new ethical channel that COMPLEMENTOS SANITARIOS, S.A. (hereinafter, COMSAN) has implemented so that its employees and suppliers can report breaches of the law or of our company’s policies, in a secure and confidential manner.

Channel Managers and Ethics Committee

COMSAN has appointed a number of people to manage and assess the communications received through the channel, and has set up an Ethics Committee to investigate the facts and resolve the procedure; COMSAN thus seeks to guarantee maximum independence, objectivity and impartiality.

The individuals responsible for the channel and those appointed to form part of the Ethics Committee are qualified to carry out the functions entrusted to them, and have knowledge of the matters that may be the subject of communication.

The channel management team is made up of the heads of some of the different departments that make up COMSAN.

Behaviours to be reported

Based on the provisions of current whistleblower protection regulations, the following are some behaviours that may and/or should be reported through the channel, in the event of becoming aware of them or being a victim of them:

Non-compliance with the code of ethics.
Fraud.
Corruption.
Criminal offences (e.g. robbery, theft, sexual assault).
Infringements in labour matters.
Conduct contrary to business interests.

On the other hand, the channel may not be used – and is not intended to be used – for the following purposes:

Contracting COMSAN products or services.
Submission of complaints and grievances.
Sending job applications.
Exercise your data protection rights.
HR-related requests.
Customer service.

Maintaining a culture of integrity and business ethics is one of our objectives and this new channel is an important tool to ensure that all stakeholders can safely and confidentially report any concerns they have about business conduct, compliance or ethics.

How to submit a communication

Communications may be submitted:

Using the form linked on our website, in the section Submit communication.

The communication shall include the identification details of the informant, basic contact details, the type of infringement reported and a description of the facts reported. It shall also be accompanied by the documents or other legally admitted and lawfully obtained means that are to be used to prove the facts.

It is also reported that the creation of an external public channel under the future Independent Authority for the Protection of Informants (A.A.I.) is planned, as an alternative to the private internal channels.

Anonymous communication:

We understand that there may be situations in which you may prefer to report without your identity being known; therefore, the channel form incorporates an option to submit the communication anonymously and confidentially, guaranteeing that your identity will not be recognised either by those responsible for the channel or members of the Ethics Committee or by third parties throughout the management, investigation and resolution process.

How to monitor the status of the procedure

The reporting person can contact the channel manager by entering the code received after the submission of the report in the review section under the web form. Open and transparent communication will be maintained with the reporter throughout the management and investigation process; the reporter will be provided with updates on the status of the investigation and any action taken in response to the report.

Communications will be handled confidentially and investigated in a fair and impartial manner.

Rights of the person making the communication

A number of rights and guarantees for the person reporting an infringement derive from the submission of the communication:

Guarantee of confidentiality, preserving their identity and that of any person in their entourage. The identity of the informant may only be communicated: to the persons authorised and designated for the management of the channel and investigation of the facts; to the competent judicial or administrative authorities, and the Public Prosecutor’s Office, within the framework of a criminal, disciplinary or sanctioning investigation.
Respect for your privacy and data protection.
Guarantee of protection against possible retaliation (e.g. suspension of contract), where the reporting person makes the report in good faith and discloses facts that he/she has witnessed or has sufficient information and evidence to believe to be true.
Right to information.
Independence, impartiality and objectivity in the management of communication and fact-finding.

Rights of the person affected by the actions

On the other hand, the person to whom the acts are attributed will also have rights and guarantees during the proceedings:

Right to the presumption of innocence and to honour.
Guarantee of independence, impartiality and objectivity in the management of communication and investigation of the facts.
Right of defence.
The right to know the facts attributed to him/her and to have access to his/her file.
Preservation of their identity.
Confidentiality guarantee.

False Allegations

In the event that, in bad faith, a communication containing false information is submitted, COMSAN reserves the right to take whatever legal action may be necessary to demand liability and compensation for any damages that may be caused.

Personal data protection

In compliance with data protection regulations, (Regulation 2016/679, General Data Protection and Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights) we inform you that the processing of the information collected in the channel is processed by COMSAN as data controller, for the purpose of investigating the facts.

Such processing is carried out on the basis of compliance with the legal obligations of the entity, as well as the exercise of a mission carried out in the public interest. Only the persons designated and authorised to manage the information will have access to it; however, the data may be communicated to the public authorities with competence in the matter within the framework of a procedure and, in the case of employees, to the legal representatives of the employees.

Los datos se conservarán en el sistema de comunicaciones internas, únicamente, durante el tiempo imprescindible para decidir sobre la procedencia de iniciar una investigación sobre los hechos comunicados, así como para la instrucción y resolución del expediente. También, se conservarán en un libro registro las comunicaciones recibidas y actuaciones realizadas durante el mínimo legal establecido.

The data shall be kept in the internal communications system only for the time necessary to decide whether to initiate an investigation into the facts reported, as well as for the investigation and resolution of the case. Also, the communications received and actions carried out shall be kept in a record book for the legally established minimum period.

For more information see our privacy policy at: https://comsan-sanitary.com/aviso-legal/.

We encourage all interested parties to use the channel. It is important for us to listen to your concerns and take appropriate action to resolve any issues. In addition, we remind you that COMSAN prohibits any form of retaliation against stakeholders who submit a communication in good faith.

If you have any questions about the channel, or if you need more information, please do not hesitate to contact us.