ETHICAL CHANNEL | Our Commitment
At HIMOINSA we know how to listen to all the people and interested parties to find out first-hand what is happening in our environment, and this attitude defines our course of action, our way of doing the right thing.
With this goal in mind, we introduce and welcome you to our Ethical Channel.
What is the HIMOINSA Ethical Channel for?
To strengthen our conduct
The existence of a bidirectional communication channel, simple and agile to use, favours compliance with our Code of Conduct, HIMOINSA's internal policies and regulations and current legislation, since it allows all relevant doubts and queries that may arise to be resolved.
To prevent and detect irregularities
Likewise, this two-way and secure communication channel enables the prevention and detection of irregular or inappropriate conduct, practices contrary to the principles and guidelines of conduct established in HIMOINSA's Code of Ethics, breaches of legislation, and any situations or events that require the attention of the Risk and Compliance Committee.
To ensure the confidentiality, security, and integrity of communications
The design of HIMOINSA's Ethical Channel guarantees (i) integrity in the traceability of the management of communications from their entry to their resolution and (ii) maximum confidentiality in the investigation processes of the communications received, protecting the identity and reputation of the informants and of any third party mentioned in the communications, as well as of the actions carried out in the management and processing of the same and preventing access by unauthorised personnel.
The Ethical Channel allows information to be communicated anonymously; however, HIMOINSA encourages informants to identify themselves and provide their contact details, as this will ensure that there is no risk of reprisals and will also allow the informant to be contacted for clarification, additional information and to follow up on the process.
The HIMOINSA Ethical Channel is not part of the Himoinsa, S.L. website or intranet; the Channel is administered and managed through an IT tool specifically designed by Lefebvre, S.A. to comply with the provisions of Law 2/2023 of 20 February, which is hosted on secure servers located in Spain that comply with ISO 27001 and ISO 9001.
Access to the information communicated through the Channel is restricted to the Risk and Compliance Committee and, where appropriate, to the external advisors that support it, who shall treat all communications with the utmost confidentiality, in accordance with applicable legislation on personal data protection and good business practices.
Who can use the HIMOINSA Ethical Channel?
THIMOINSA's Ethics Channel is available to anyone related with the Company.
For more information on the personal scope of the Channel, please refer to the Ethical Channel General Policy.
At any time the user of the Channel may renounce or desist from the communication made.
Good use of the Channel
HIMOINSA's Ethics Channel is governed by the principle of good faith, which means that at the time of making the communication, the informant must have reasonable grounds to believe, in view of the circumstances and the information available to him/her, that the facts to be communicated are true and fall within the scope of application of the Channel.
HIMOINSA will provide protection, within its organisational structure, against retaliation of any kind to any whistleblower who has acted in good faith.
Anyone using the Ethics Channel in a malicious, frivolous or abusive manner, or deliberately and knowingly communicating incorrect or misleading information, knowing it to be false or with manifest disregard for the truth, shall not be protected. When the internal investigation opened as a result of a communication received through the Ethical Channel concludes that any of these circumstances are present, HIMOINSA, as guarantor of the credibility of the Internal Reporting System, may take legal action or adopt the proportional disciplinary measures it deems appropriate, thereby waiving its duty of confidentiality.
Accusation, false accusation and simulation of offences are considered offences punishable by imprisonment for up to two years.
The Ethics Channel is also not a police or emergency service, so if you need to report a critical situation you should contact the appropriate emergency services.
What issues are excluded from the scope of the Ethics Channel?
Matters relating to disputes arising in connection with the following issues are outside the scope of the Ethics Channel:
a) Complaints about the organisational or operational management of a business area, which must be dealt with within the Company's organisational structure.
b) Commercial complaints from suppliers or customers, which must be submitted through the following channels: Suppliers; compras@himoinsa.com International Clients; sales_administration@himoinsa.com
c) Complaints concerning after-sales service, which should be addressed to postventa@himoinsa.com
d) Complaints regarding ordinary labour and human resources management issues, which should be addressed to the corresponding Human Resources Departments of Himoinsa, S.L. or its subsidiaries, as the case may be.
e) Complaints about interpersonal disputes or disputes involving only the reporter and the persons to whom the communication relates, which should be addressed to: rrhh@himoinsa.com
f) The exercise of the rights of access, rectification, cancellation and opposition, as well as those of rectification and portability, which should be addressed to: privacy@himoinsa.com
Who manages the Channel?
The Ethics Channel is administered and managed by the HIMOINSA Risk and Compliance Committee which, as the System Manager, has full autonomy and independence. In cases of particular complexity or when the facts reported affect or may affect several departments, the external advisors of the Risk and Regulatory Compliance Committee may collaborate in the instruction of the process. When it is noted that the communication received directly affects persons who may be actively involved in the management and investigation of the same, they shall be automatically excluded from the entire process of investigation and analysis until its resolution, in order to avoid any type of conflict of interest or incompatibility, and to guarantee the objectivity and independence of the actions carried out by the Committee itself.
