Ethical channel

COOVER wishes to establish a culture of transparency, ethics and zero tolerance to behaviours that may involve a breach of the applicable legislation or internal regulations.

The Ethics Channel is an internal communication system available to those persons who are aware in a work or professional context of conduct that may infringe regulations and who wish to report it, providing guarantees of confidentiality and adequate protection against possible reprisals.

 

Access to the Ethical Channel

The preferred form for submitting complaints is the form provided. However, complaints may be made in writing, by post, orally in person or by telephone or voice messaging system.

If so desired, the complaint can be made anonymously, but this type of complaint implies that the level of detail of the communication made must be sufficiently exhaustive for it to be admitted for processing.

    INTEREST GROUP:


    TEXT OF THE COMPLAINT:


    UPLOAD EVIDENCE:

    Name

    Surname

    Telephone

    Email

    privacy policy

     


    Personal data are processed by ENVAPLASTER S.A. with address at Pol. Alberguería · C/ Javier Indave, No. 3, C.P. 31230 Viana (Navarra) and with CIF A26074948 with your consent or other legitimate basis. The purpose is to comply with your request. They will not be transferred, unless justified and will be kept as long as there is a legal basis for their maintenance. You can exercise your rights in the terms indicated in privacy policy


    Acknowledgement of receipt: Once the complaint has been received, it will be assigned an identification code.

    FAQs

    Content of the complaint

    The communications shall have at least the following content, subject to certain sections being voluntary

    • If not anonymous, Identification of the informant: name and means of contact either by email or telephone in order to collect further information if necessary and to keep you informed of the status of the report.
    • Identity of the accused: if known, name and surname, as well as any other data known and considered relevant for identification.
    • Reason for the complaint: description of the facts or circumstances that in the informant’s opinion constitute a non-compliance or irregularity.
    • Concrete evidence to support the complaint: all documents available to support the alleged act.

    Admissibility / Inadmissibility of the complaint

    Once the complaint has been received, the COOVER Ethics Committee will study and process it.

    • Admissibility: Only complaints that clearly and obviously state, or provide sufficient information to investigate, facts constituting an infringement, irregularity or breach of current legislation, policies, rules, codes or any other internal procedure will be admitted for processing.
    • Inadmissibility: Complaints that do not contain all the required information, do not constitute an infringement or non-compliance, or do not provide sufficient clarity or detail to determine whether a potential irregularity exists will not be admitted for processing.

    In the case of both admissible and inadmissible complaints, this shall be communicated to the informant if he/she has provided a form of communication.

    If the complaint is rejected, the complainant may consider reformulating the complaint or using alternative legal avenues that he/she considers appropriate, including external reporting channels.

    Guarantees of the Channel and the investigation process

    All complaints received through the internal reporting channels shall comply with the following principles and guarantees:

    a) Security measures: the Internal Information System shall have appropriate technical and organisational security measures in place to prevent the risk of disclosure, unavailability and loss or destruction of information, i.e. the confidentiality, availability and integrity of the reports received shall be ensured.

    b) Confidentiality: The confidentiality of the identity of the informant, the reported person, the persons concerned and any third party mentioned in the communication, as well as the facts mentioned, shall be guaranteed, and only authorised personnel shall have access to the communication.

    c) Protection of personal data: the processing of personal data will be carried out in accordance with current data protection legislation.

    d) Prompt and reasoned response: communications will be answered within the established deadlines.

    e) Absence of conflicts of interest: communications received will be treated in an impartial and objective manner, taking into account the reality of specific facts and, where appropriate, avoiding conflicts of interest.

    Whistleblower Rights and Guarantees

    Whistleblowers shall have the rights of confidentiality of their identity, anonymity in making the report and non-reprisals. The Ethics Committee, together with the corresponding departments, will establish the appropriate follow-up actions to ensure compliance with these guarantees.

    Guarantees and Rights of the Complainants

    Those accused shall have the rights of confidentiality, presumption of innocence, information, the right to testify, to present evidence and to assistance, and the right to a fair procedure. The Ethics Committee, together with the relevant departments, shall establish the appropriate follow-up actions to ensure compliance with these guarantees.

    External information channels

    External reporting channels: Channels created within competent entities and authorities through which Reporters can report breaches, irrespective of whether the Ethics Channel has been used or not.

     

    1. European level
    • European Anti-Fraud Office (OLAF):

    It allows the submission of Communications, including anonymously, through the following channels:

    1. Online: https://fns.olaf.europa.eu/main_es.htm
    2. By post to the following address: European Commission – European Anti-Fraud Office (OLAF)1049 Brussels, Belgium

     

    • European Public Prosecutor’s Office (EPPO):

    Communications can be submitted through the following link, anonymous communications are not accepted: https://www.eppo.europa.eu/es/form/eppo-report-a-crime

     

    1. National level
    • National Anti-Fraud Coordination Service (SNCA)

    Communications can be submitted through the following link, anonymous communications are not accepted: https://www.igae.pap.hacienda.gob.es/sitios/igae/es-ES/snca/Paginas/inicio.aspx

    • Independent Authority for Whistleblower Protection, I.A.P.P. (pdte. creation 231108)