INTERNAL INFORMATION CHANNEL PROCEDURE

Object
The purpose of this procedure is to regulate the operation of the Marsan Group's Internal Information System, ensuring the receipt, management, and investigation of communications received, the protection of whistleblowers, and compliance with Law 2/2023, of 20 February, and other applicable regulations (labour, criminal, and data protection).

Scope of application
This procedure shall apply to employees, managers and directors, as well as external collaborators, suppliers and third parties with professional ties.

SYSTEM PRINCIPLES
The system shall be governed by the principles of information and informant identity confidentiality, prohibition of retaliation, possibility of anonymity, informant good faith, independence and impartiality, and personal data protection.

SYSTEM RESPONSIBLE
The company designates a head of the Internal Information System (HIS) and a deputy head.
The RSII receives and manages communications, decides on their admission or inadmission, coordinates investigations and ensures confidentiality and adherence to deadlines.
The substitute shall act in case of absence, conflict of interest or impossibility of the incumbent. Should the communication directly or indirectly affect the RSII, management shall be automatically assumed by the substitute.

Reception channels
Communications can be submitted via a digital platform (preferred channel), a specific email address, a telephone channel or mailbox, or in person by appointment. Staff will be informed of the available channels.

Communication Content
The communication shall include, as far as possible, a description of the facts, date or period, persons involved and available evidence. The submission of full proof shall not be necessary for its admission.

Acknowledged
An acknowledgement of receipt will be sent within a maximum of 7 calendar days, unless doing so would jeopardise confidentiality or the informant has opted for anonymity without a response channel.

Admission of proceedings
The RSII will analyse the communication and decide whether to accept it for processing or reject it with reasons.

Reasons for inadmissibility
The communication may be inadmissible due to lack of minimal content, manifestly unfounded facts, absence of an infringement, matters outside the scope of the channel (ordinary labour claims, administrative requests or organisational conflicts), repetition without new elements, bad faith or lack of competence of the system. Inadmissibility cannot be based solely on the absence of evidence if there are reasonable indications. It will be reasoned and, where appropriate, the informant will be informed of the appropriate channel.

INVESTIGATION
The investigation will only be initiated in the case of admission to proceedings.
Instructor Designation The designation of the instructor may be carried out by the RSII or by a designated instructor, whether internal or external, ensuring impartiality. Actions These may include the collection of evidence, interviews, and documentary analysis. Precautionary Measures Provisional precautionary measures may be adopted, which must be proportional, temporary, and respectful of labour regulations, without constituting an advance sanction.

The affected person's rights will be guaranteed the right to be informed of their rights at the appropriate time, to be heard and to present allegations, the presumption of innocence, and the protection of their honour, privacy, and reputation. The informant's identity shall not be disclosed under any circumstances.

Deadlines
The procedure must be resolved within a maximum of 3 months from acknowledgment of receipt or, failing that, from the expiry of 7 days from receipt, and may be extended to 6 months in complex cases.

RESOLUTION
The final report shall include facts, conclusions and recommendations. It may be agreed to archive, take disciplinary or organisational measures or communicate to competent authorities.

COMMUNICATION TO THE INFORMANT
The status or outcome of the procedure will be reported, respecting confidentiality and data protection regulations.

Whistleblower Protection
Protection against retaliation, protection from unjustified negative consequences, and the adoption of support measures where appropriate, are guaranteed.

Data Protection
The treatment will be carried out in accordance with the GDPR and the LOPDGDD. Access will be limited to the RSII and to the persons necessary according to the nature of the facts, applying the principle of minimisation. Data will be kept for a maximum of 3 months if no investigation is initiated and for the necessary time otherwise.

COORDINATION WITH OTHER CHANNELS
The system will be coordinated, where appropriate, with the harassment protocol, health and safety at work risk prevention, disciplinary procedures, and the legal representation of workers.

REGISTER AND TRACEABILITY
An internal record will be kept to ensure the traceability of communications, their monitoring, and the retention of evidence for audit purposes.

TRAINING AND AWARENESS
The company will ensure the training of managers and key personnel, as well as the dissemination of the channel and staff awareness.

PROCEDURE REVIEW
The procedure will be reviewed at least annually or when relevant regulatory or organisational changes occur.

Territorial scope
This procedure shall apply in Spain, and may be adapted for other group companies in accordance with applicable local regulations.

Grupo Marsan is a Tier 2 supplier of industrial coatings, cataphoretic coating, powder coating, liquid painting, metal stamping, assembly, and JIT logistics with plants in Spain, Portugal, and Mexico.

Capabilities

Cataphoresis
Powder coating
Liquid paint
Stamping and welding
Logistics services
Technology centre

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Public funds

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Capabilities
Plants
Quality
Request a quote
More information
Public funds

Contact

Vigo Technological and Logistics Park,
Calle B, Plot 10.09, 36314 Vigo.

Email: info@grupomarsan.com
Telephone: +34 986 27 08 04
Opening hours: Mon-Fri 9:00 - 17:00

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