Internal information system

Introduction

 
Asterion Industrial Partners, S.G.E.I.C., S.A. has implemented an Internal Information and Informant Protection System, which is one of the key elements for supervision, control and prevention of risks in the area of regulatory compliance.

The main purpose of this System is to enable any person related to the Entity's activity to inform or communicate:
  1. on the existence of indications, suspicions or facts relating to the commission of offences, irregularities or risks which imply a breach of the regulations applicable to the Entity
  2. any suspicious transaction in the area of money laundering and terrorist financing
  3. any indication, suspicion, or evidence of unethical, discriminatory, or irregular behaviour and possible harassment at work and/or sexual harassment
  4. any fact, indication, irregularity, risk, or non-compliance with data protection regulations
  5. any other fact that goes against the policies and procedures of the Entity, the Law or ethics
   

Communications within the scope of Law 2/2023

 
If communications within the scope of Law 2/2023 of 20 February 23 regulating the protection of persons who report regulatory infringements and the fight against corruption are submitted, the informant will be protected with retaliation protection measures, provided such person has obtained information about the potential offence in an employment or professional context when dealing with Asterion.


Said law is applicable to communications regarding acts or omissions that may constitute a serious or very serious criminal or administrative offence, or which may constitute an infringement of European Union Law provided that they:
  1. fall within the scope of the acts of the European Union listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019
  2. affect the financial interests of the European Union; or
  3. impact the internal market.
  In the event that information outside the scope of application of said Law is communicated, Asterion will pursue its investigation, but the informant will not necessarily be covered by retaliation protection measures.
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General principles applicable to the System

 
The System is governed by the following essential principles and guarantees:
  • Confidentiality and data protection compliance
  • Independence and absence of conflict of interest
  • Absence of retaliation against the informant
  • Anonymity
  • Easy accessibility and user-friendly System
   

Communication Channels

 
The Entity has two internal channels for receiving information:
  1. the main one consisting of an electronic mailbox configured in an online platform managed externally by Informa Consulting, which is accessible through the following URL address: http://compliance.informaconsulting.com/FormularioPublico/LadingPage?Token=50e61b09-0a9d-473d-a61b-860f353f52b8,
  2. an alternative channel, at the request of the informant, consisting of the possibility of requesting a face-to-face meeting with the persons responsible for the System by emailing the following address: compliance@asterionindustrial.com
 
In order to file a communication via the electronic mailbox, the fields to complete (which are not compulsory) are the following:
  • Type of communication
  • Statement of facts: it is recommended that the narrative be clear, concise, providing all the information available relevant to the object of the communication
  • Time of occurrence, persons involved and whether the reported event is still occurring
  • Contact information of the informant: name, relationship with Asterion, email address and telephone number


The System allows for the introduction of anonymous communications. Once the Investigation Committee designed to investigate the information received, has been appointed (if appropriate) further information may be gathered through inquiries or investigations that may be necessary to clarify the facts and obtain the necessary evidence to resolve the communication.
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Download our Internal information system policy in Spanish below

Download PDF in Spanish

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