In compliance with Law 2/2023, of 20 February, on the protection of persons who report regulatory infringements and the fight against corruption, OREMFI BY ASERPRO, S.L. makes this Internal Reporting Channel available to its stakeholders as a secure and confidential means of reporting potential irregularities.
What is this channel?
This Internal Reporting Channel is a secure and confidential tool through which any person who, in the context of their employment or professional relationship with OREMFI BY ASERPRO, S.L., becomes aware of potential regulatory infringements, may report them in a protected manner.
Reports may be submitted either on an identified or anonymous basis. In both cases, the confidentiality of the information and the protection of the reporting person against any form of retaliation are guaranteed.
Who can use this channel?
This channel may be used by any natural person who maintains or has maintained an employment or professional relationship with OREMFI BY ASERPRO, S.L., including:
- Current and former employees.
- Candidates who have participated in recruitment processes.
- Trainees, volunteers, and persons undergoing work-based training.
- Suppliers, subcontractors, and their employees.
- Shareholders, members of the board of directors, management, or supervisory bodies.
- Any person working under the supervision of contractors or suppliers of the organisation.
What type of reports can be submitted?
This channel may be used to report actions or omissions that may constitute:
- Criminal offences.
- Serious or very serious administrative infringements.
- Breaches of European Union law in the areas covered by the applicable regulations.
Reports must relate to facts that came to the reporting person's attention in the context of an employment or professional relationship with the organisation. The reporting person must have reasonable grounds to believe that the information provided is truthful.
This channel must NOT be used for:
- Personal complaints or customer claims.
- Interpersonal conflicts between employees.
- Suggestions or improvement proposals.
- Information based on mere rumours without reasonable grounds.
- Deliberately false or misleading reports.
Safeguards for reporting persons
- Confidentiality: The identity of the reporting person and of any third party mentioned in the report shall be treated in the strictest confidence. Only the System Manager shall have access to this information.
- Anonymity: Reports may be submitted anonymously. In such cases, no data that could identify the reporting person shall be collected.
- Protection against retaliation: Any form of retaliation is prohibited, including dismissal, sanctions, demotion, intimidation, harassment, or ostracism, against persons who submit reports in good faith.
- The identity of the reporting person may only be disclosed to the judicial authority, the Public Prosecutor's Office, or the competent administrative authority in the context of an investigation.
How does the procedure work?
1. Submission of the report: Complete the form available below on this page, providing as much information as possible about the facts.
2. Acknowledgement of receipt: An acknowledgement of receipt shall be issued within a maximum period of 7 calendar days from receipt of the report.
3. Assessment and admission: The System Manager shall assess the admissibility of the report and, where appropriate, initiate the relevant investigation measures.
4. Communication of the outcome: The reporting person shall be informed of the outcome of the investigation within a maximum period of 3 months from the acknowledgement of receipt.
Internal Reporting System Manager:
José Pineda Cuenca
info@aserproconsulting.com
External reporting channel
In addition to this internal channel, reporting persons may address their report to the Independent Authority for the Protection of Reporting Persons (Autoridad Independiente de Protección del Informante — AIPI) through its website: https://aipi.gob.es
They may also contact, where applicable, the competent regional authority for the protection of reporting persons.
The internal channel is the preferred reporting mechanism under the law, but reporting persons have the right to choose the channel they consider most appropriate given the circumstances.
Data protection information
Data controller: OREMFI BY ASERPRO, S.L., with tax identification number B54906425 and registered address at Calle Apolo, 26, 2º-4, 03182 - Torrevieja, Alicante (España).
Purpose: To manage reports received through the Internal Reporting Channel, including receipt, admissibility assessment, investigation of the reported facts, and, where appropriate, the adoption of corrective measures. The personal data collected shall be strictly and objectively limited to what is necessary to process the reports and shall not be used for incompatible purposes.
Legal basis: Compliance with a legal obligation applicable to the data controller, pursuant to Law 2/2023, of 20 February (Art. 6(1)(c) GDPR). Where special categories of personal data are processed, the legal basis shall be substantial public interest in accordance with Art. 9(2)(g) GDPR.
Recipients: Data shall be processed by the Internal Reporting System Manager. Where necessary, data may be disclosed to the Data Protection Officer, the head of the legal department, the body responsible for handling potential disciplinary proceedings, and the judicial authorities, the Public Prosecutor's Office, or the competent administrative authority in the context of an investigation. No international data transfers shall be made.
Retention: Data shall be retained for the time strictly necessary to determine whether an investigation should be initiated, and in no case for a period exceeding ten years. If no investigation has been initiated within three months of receipt of the report, the personal data shall be deleted, unless retention is necessary to evidence the proper functioning of the system. Reports that are not processed may only be retained in anonymised form.
Rights: You may exercise your rights of access, rectification, erasure, restriction, objection, and portability by contacting info@aserproconsulting.com. The reported person's right of access is limited and shall not extend to the identity of the reporting person.
Data Protection Officer: info@aserproconsulting.com
Complaints: You may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos — www.aepd.es).