Internal Information System

ALTING S.A., hereinafter the Company or ALTING, seeks to create an environment of transparency and encourage respect for the law and standards of conduct established in our Code of Conduct by our directors, professionals, and suppliers.

To this end, it has an Internal Information System to facilitate the reporting of possible irregular behavior or potential illicit acts or acts contrary to the law or the Governance and Sustainability System, whose essential principles are the following:

  • PROHIBITION OF RETALIATION: ALTING undertakes not to adopt any form of retaliation against any person who has made a communication in good faith.
  • ANONYMITY: Communications can be made completely anonymously.
  • CONFIDENTIALITY: ALTING will ensure that the personal information in the communications submitted will be protected and not disclosed without the prior written consent of the Consent of the informant.
  • RIGHTS OF AFFECTED PERSONS: The rights to privacy, honor, defense, and the presumption of innocence of the investigated and affected persons are guaranteed.

What is the Informant Channel?

The Informant Channel is the mechanism that ALTING makes available to all informants so they can report any conduct as established in our Informant Channel Management Policy. Therefore, we recommend that you consult the Informant Channel Management Policy.

This channel is not for complaints and/or claims regarding the service received from ALTING. The following email address is available for this purpose: barcelona@alting.com

What is meant by an informant?

  • ALTING employees, managers, and the governing body.
  • Interns,
  • Temporary employment agency workers,
  • Collaborators,
  • Suppliers and people who work for or under their supervision,
  • Shareholders,
  • Former employees,
  • Job candidates,
  • Third parties with whom any type of relationship or link may exist, and
  • Any third party that has detected misconduct Unlawful.

Who can be reported?

All ALTING employees, directors, management bodies, or external collaborators under your authority who have committed any irregularity or conduct described in the objective scope detailed in the Whistleblower Channel Management Policy may be reported or disclosed.

What conduct can be reported?

The conduct that can be reported is collected and detailed in the Annex included in the Whistleblower Channel Management Policy and listed below:

  • Workers’ rights
  • Personal data protection
  • Sexual assault or harassment
  • Good reputation of the company and its employees
  • Health and risk prevention
  • Corruption in business
  • Money laundering
  • Conflict of interest
  • Environment
  • Equality
  • Tax obligations
  • Intellectual property
  • Accounting or documentary falsification
  • European Union law
  • Other

What is the reporting process?

Any person with access to the Internal Information System may direct their communication to ALTING’s Whistleblower Channel, in compliance with the principle of good faith. fe.

Once the informant accesses the platform, they will read a brief description of the Informant Channel. To submit their report, they must read, understand, and accept the following documents: the Channel User Manual, the Communications Management Procedure, and the Privacy Policy.

Once they have access, the channel requests the following prior information:

  • Type of communication you wish to submit
  • Whether or not it is urgent
  • Relationship the informant has with the entity
  • Areas considered to be violated (optional)
  • You must also enter a password designed for the occasion, which must be repeated to continue.

Next, you will select whether the communication will be made via a written form or a personal interview.

Once you have selected the communication method, you can choose between:

Anonymous communication. The person making the communication will not have to provide any personal information. Since notifications (communication status changes, requests, etc.) cannot be sent to them, they will have to access their communication in the channel to check if they exist.

Semi-anonymous communication. The person making the communication will have to provide their personal information, but this will not be communicated to the entity. You may receive notifications at the email address you provide, and your information will not be disclosed to the entity unless you have acted in bad faith.

Non-anonymous communication. The person making the report will provide their personal information to the entity and will receive notifications at the email address provided.

Once this option is selected, the form must be completed by filling out the following fields:

  • Indicate when it occurred or if it is still occurring
  • Description of the events
  • Who is aware of the events
  • Which people or departments are involved
  • Password reminder for follow-up

The reporter may also answer additional questions providing more information and may attach files that document and prove their report. The reporter may also choose to expand the information and documentation of the report after submitting it, either voluntarily or at the request of the System Manager. New facts and documentation provided will be considered in the management process.

In the case of communications submitted through channels other than the Whistleblower Channel platform, whether they are communications made by the whistleblower themselves or those sent to the System Manager by the channel or the recipient not responsible for management, they will be incorporated into the corporate Whistleblower Channel once the information has been obtained.