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:
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.
Any suspicious transaction, in the area of money laundering and terrorist financing,
Any indication, suspicion, or evidence of unethical, discriminatory, or irregular behavior and possible harassment at work and/or sexual harassment.
Any fact, indication, irregularity, risk, or non-compliance with current data protection regulations.
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:
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;
Affect the financial interests of the European Union; or
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.
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
Easy accessibility and user-friendly System
Which are the main channels of communication
The Entity has two internal channels for receiving information:
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.
KEY TOPICS OF OUR ESG APPROACH
Please click here to download our Responsible Investment Policy
This website uses its own and third-party cookies, which are strictly necessary, as well as analytical cookies, which are the responsibility of Asterion Industrial Partners SGEIC, S.A. (hereinafter, “Asterion”), to facilitate and improve your navigation, for security reasons, and traffic analysis.
Please, click on “Accept”, to accept the Privacy and Cookies Policies of this website.
Este sitio web utiliza cookies propias y de terceros, estrictamente necesarias, así como cookies analíticas, responsabilidad de Asterion Industrial Partners SGEIC, S.A. (en adelante, “Asterion”) para facilitar y mejorar su navegación, por motivos de seguridad, y análisis de tráfico.
Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information.
Any cookies that may not be particularly necessary for the website to function and is used specifically to collect user personal data via analytics, ads, other embedded contents are termed as non-necessary cookies. It is mandatory to procure user consent prior to running these cookies on your website.