Internal information system


Asterion Industrial Partners, S.G.E.I.C., S.A. has implemented an Internal Information and 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 possible 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 behavior and possible harassment at work and/or sexual harassment.
  4. Any fact, indication, irregularity, risk, or non-compliance with current data protection regulations.
  5. Any other fact that goes against the policies and procedures of the Entity, the Law or ethics.

What type of information can be communicated

The System applies to any communication made by a reporting person which involves an act or omission that may constitute a serious or very serious criminal or administrative offence, or which may constitute an infringement of European Union Law provided that:
  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 on the internal market.
  In the event that information outside this material scope of application is communicated, Asterion reserves the right to pursue its investigation, but the informant would not be covered by retaliation protection measures. The System applies to informants who have obtained information about an offence in an employment or professional context.
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General principles for action of the communication system

  • 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

Which are the main channels of communication

The Entity has two internal channels for receiving information:
  1. Main one consisting of an electronic mailbox configured in an online platform managed by Informa Consulting, which is accessible through the URL address:,
  2. An alternative channel, at the request of the informant, consisting of the possibility of requesting a face-to-face meeting with those responsible for the System.
The topics to complete required by the System but not mandatory are the following:
  • Type of communication.
  • Statement of facts: it is recommended that the narrative be clear, concise, providing all available information relevant to the subject matter.
  • Time of occurrence, persons involved and whether the reported event is still occurring.
  • Contact of the informant: Name, relationship with the Entity, email and telephone number.
  The System allows for the introduction of anonymous complaints. Once the Commission of Inquiry, designed to investigate de 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.
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