Internal Reporting Channel
ITE Internal Reporting Channel
INTEGRACIÓN TECNOLÓGICA EMPRESARIAL, S.L. (ITE) has an Internal Information System (IIS) in accordance with Law 2/2023 of 20 February on the protection of persons who report regulatory and legal breaches and the fight against corruption.
The Internal Information System is intended to facilitate the secure and confidential reporting of potential breaches or irregular conduct relating to ITE, ensuring the proper handling of the information received and the protection of reporting persons under the terms established by law.
The System is managed by the Person Responsible for the Internal Information System (RIIS) independently, autonomously and confidentially.
What can be reported?
Through the Internal Information System, the following may be reported, among others:
- acts or omissions that may constitute breaches of European Union law, under the terms provided for in Law 2/2023;
- facts that may constitute a serious or very serious criminal or administrative offence;
- serious or very serious criminal or administrative offences involving financial loss to the Public Treasury or the Social Security system;
- potential breaches of ITE’s Code of Ethics, policies, rules or internal procedures; and
- other irregular conduct or internal breaches that may be relevant to the organisation.
Reports concerning matters falling outside the scope of Law 2/2023 may be handled internally by ITE, although they will not be subject to the specific protection regime provided for under that Law.
Where the reported facts fall within a specific internal procedure, such as the Protocol for the Prevention of Harassment, the report will be appropriately referred and handled in accordance with the applicable procedure, while the safeguards provided for under Law 2/2023 will be maintained where applicable.
Who can use the channel?
The Channel may be used by persons who have obtained information about potential breaches in a work-related or professional context involving ITE, including, among others:
- employees;
- self-employed persons;
- shareholders, members and members of the management, governing or supervisory body;
- persons working for contractors, subcontractors or suppliers;
- former employees or collaborators;
- volunteers, interns and trainees; and
- persons who obtained the information during a recruitment process or pre-contractual negotiations.
The Channel may also receive reports from customers, collaborators, business partners and other third parties connected with ITE who become aware of facts that may be reported.
How can a report be submitted?
Reports may be submitted in writing or orally, either identified or anonymously.
By email
Via: denuncia-acoso@ite-es.com
Access to this mailbox is restricted to the Person Responsible for the Internal Information System.
By post
By sending a report to:
Person Responsible for the Internal Information System
INTEGRACIÓN TECNOLÓGICA EMPRESARIAL, S.L. (ITE)
C/ Navia, 6
28670 Villaviciosa de Odón (Madrid)
Spain
The following may be stated on the outside of the envelope: CONFIDENTIAL – PERSON RESPONSIBLE FOR THE INTERNAL INFORMATION SYSTEM
By telephone
By calling the Person Responsible for the Internal Information System directly:
Telephone: +(34) 691 438 593
This number will be answered directly by the Person Responsible for the System.
In person
The reporting person may request an in-person meeting with the Person Responsible for the Internal Information System, which will be held within a maximum period of seven days from the date of the request.
The meeting may be requested through any of the contact methods indicated above.
Anonymous reports
ITE’s Internal Information System allows reports to be submitted and handled anonymously.
The reporting person is not required to disclose their identity for the information to be analysed and, where appropriate, investigated.
Where a report is anonymous and no secure means of contact is provided, it may not be possible to request additional information or subsequently communicate the outcome of the proceedings.
Confidentiality
ITE guarantees the confidentiality of the whistleblower’s identity, the persons concerned and any third parties mentioned in the reports.
The identity of the reporting person will not be disclosed to the person concerned by the report.
Access to reports and case files will be restricted to the Person Responsible for the System and to those persons whose involvement is necessary and legally authorised.
Whistleblower protection
ITE prohibits any form of retaliation, threat or attempted retaliation against persons who report information under the conditions provided for in Law 2/2023.
Legal protection applies to persons who have reasonable grounds to believe that the information reported was truthful at the time the report was made, even if the facts cannot subsequently be substantiated.
The fact that the reported facts cannot be substantiated does not, in itself, mean that the information was false or that the reporting person acted in bad faith.
What happens after a report is submitted?
The report will be recorded and analysed by the Person Responsible for the Internal Information System.
Where the reporting person has provided a means of contact, an acknowledgement of receipt will be sent within seven calendar days of receipt, unless this could compromise the confidentiality of the report.
During the proceedings, the reporting person may be asked to provide additional information or documentation where necessary.
Where appropriate, the necessary investigative actions will be carried out to verify the reported facts, respecting the rights of all persons involved and, in particular, confidentiality, the presumption of innocence, the right to honour and the right of defence.
The maximum period for responding to the investigative proceedings will be three months, which may be extended by a maximum of a further three months in cases of particular complexity.
Where the reporting person has provided a means of contact and has not waived the right to receive communications, they will be informed of the conclusion of the proceedings and, where legally appropriate, of their general outcome.
Rights of the persons concerned
The handling of a report does not imply that the reported facts are true, nor does it entail the attribution of any liability.
The persons concerned have the right to be informed of the acts or omissions attributed to them, to make representations, provide documents and evidence, be heard and properly exercise their right of defence.
At all times, their presumption of innocence, right to honour and protection of personal data will be respected.
The identity of the reporting person will not be disclosed to the person concerned.
Personal data protection
Personal data processed through the Internal Information System will be used exclusively for the management, investigation and resolution of the reports received and for compliance with the obligations established under Law 2/2023 of 20 February and other applicable legislation.
The data controller is INTEGRACIÓN TECNOLÓGICA EMPRESARIAL, S.L. (ITE).
Access to personal data contained in the Internal Information System will be restricted to persons expressly authorised in accordance with Law 2/2023 and solely within the scope of their respective powers and duties.
Data subjects may exercise the rights afforded to them under data protection legislation and contact ITE’s Data Protection Officer (DPO) at: dpo@ite-es.com
This address is provided exclusively for matters relating to the protection of personal data and the exercise of the corresponding rights. It does not constitute a channel for submitting reports or information concerning potential breaches.
Reports concerning potential breaches must be submitted through the channels provided by the Internal Information System indicated above and, in particular, by email to denuncia-acoso@ite-es.com
In all cases, the confidentiality of the identity of the reporting person, the persons concerned and any third parties mentioned in the report will be guaranteed in accordance with the terms established by law.
External reporting channels
The use of ITE’s Internal Information System is not a prerequisite for accessing legally established external reporting channels.
Reporting persons may submit their reports to the Independent Authority for the Protection of Reporting Persons (A.A.I.) (AIPI), or to the competent regional authority depending on the territorial scope of the reported facts and, where applicable, to the institutions, bodies or agencies of the European Union.
Up-to-date information on the AIPI External Reporting Channel is available on the official website and electronic office of that Authority.
Internal information system policy
ITE has an Internal Information System and Reporting Person Protection Policy, which establishes the principles and safeguards applicable to the operation of the System.
→ View the Internal Information System and Reporting Person Protection Policy