Complaints channel

Introduction

ARAVINC, S.L. has a complaints channel so that those who are aware of serious infractions or crimes committed during the exercise of their activity or relationship with the company can report them. The channel is the communication tool that integrates the internal information system of the organization.

Who can report/complain through the whistleblower channel?

Current or former employees of the company. Different types of personnel: volunteers; scholarship; in training periods; nominations; freelancers; partner people; personnel of contractor companies, subcontractors, suppliers; legal representatives of the workers or natural persons who advise the reporting person; natural persons who are related to the reporting person and who may suffer reprisals, such as co-workers or relatives of the reporting person; legal persons, for whom they work or with whom they maintain any other type of relationship in a work context or in which they hold a significant participation.

What can be reported
  • Actions or omissions that may constitute breaches of European Union Law.
  • Actions or omissions that could constitute a serious or very serious criminal or administrative offense.
  • Infringements of labor law in the area of occupational health and safety.

This channel is not an instrument of communication of labor or commercial complaints between parties.

The channel must be used in good faith. If the complainant acts with awareness of the lack of veracity of the data provided, or with the sole purpose of denigrating the person or institution denounced, he/she may be held liable.

Confidentiality and non-retaliation

This system guarantees the confidentiality of the complainant and of any third party that appears in the communication, both legally and technically, and allows anonymity. Likewise, the system is subject to the principle of non-retaliation for any of the complainants or third parties. When the organization becomes aware that the whistleblower or informant has been subjected to acts of intimidation or retaliation, it will promote or exercise the appropriate corrective or restitutionary actions.

Anonymous reporting

The report may be anonymous; the most important thing is the credibility of the facts, not the person making the report. Anonymity, however, makes it difficult to maintain an open communication channel with the complainant, which would facilitate the analysis and investigation process. Likewise, depending on the type of offense reported (especially if it directly affects the complainant), anonymity can also make the investigation much more difficult.

Processing of the complaint

Sending the complaint automatically generates a reception number available to the complainant. The complaint is transferred to the person responsible for the company’s complaint systems, beginning the analysis and investigation phase. The procedures will be carried out with the utmost reserve and confidentiality, in accordance with the law. Within a maximum period of three months (extendable to a further 3 months in the event that the investigation is particularly complex), the company will notify the complainant of the content of the resolution derived from their complaint. It is possible to maintain communication with the complainant or request additional information. If its investigations reveal indications of a crime, the facts will be transferred to the Public Prosecutor’s Office or the judicial authority.