1. PURPOSE AND SCOPE
The purpose of this REGENERA procedure is to respond to situations of whistleblowing and complaints within the scope of this organisation, applying to all persons providing services in the organisation, including trainees and external collaborators.
REGENERA, by implementing this procedure, assumes its commitment to prevent, not tolerate, combat and prosecute any manifestation of the aforementioned conduct within its organisation.
The company will sanction anyone who engages in offensive conduct as well as anyone who promotes, encourages and/or tolerates it. All company personnel are obliged to respect the fundamental rights of all REGENERA employees, as well as those who provide services to the company. In particular, they will refrain from behaviour that is contrary to the integrity, dignity, privacy and the principle of equality and non-discrimination, always promoting respectful conduct.
2. PRINCIPLES
This procedure is based on the principles of:
a. Confidentiality throughout the process, The process must guarantee that all the information provided must not be used by any of the parties involved in the process for purposes other than the purpose of the process. The data must be considered as data protected by the Organic Law on the Protection of Personal Data, on the understanding that they must have special protection to the extent that they affect the privacy of the individual.
b. Protection against retaliation, against anyone making a bona fide communication.
c. Agility and speed, The response to situations of conflict must be rapid, in such a way that it meets the expectations of the person affected, allows the appropriate precautionary measures to be taken and immediately prevents the situations generating the conflict from being prolonged over time, transforming situations that can be brought back into others that could cause serious harm to the worker.
d. Impartiality. Appointment of external and impartial staff who will comply in a comprehensive manner with impartiality towards the affected parties..
e. Protection of the persons involved, the persons named in the complaint have the right to:
- Be informed at the right time.
- To be aware of the facts with which they are charged.
- Be heard and provide evidence.
- Presumption of innocence and protection of their identity.
3. PROCEDURE
- Prevention and awareness-raising.
✓ Training and dissemination of the protocol to all staff.
✓ Inclusion of preventive measures in the organisational culture.
- Receipt of the complaint
✓ E-mail is enabled In order to guarantee the confidentiality of any complaint, claim or communication. REGENERA provides the following e-mail address canaldenuncias@regeneraenergy.es and telephone number 647884957 to which only the person in charge of handling the complaint or claim and the members of the investigating committee will have access, and whose purpose is solely and exclusively the presentation of this type of complaint or claim. complaints or claims.
✓ Possibility for the complaint to be made verbally or in writing. Complaints or claims may also be accepted in secret, in writing and in a sealed envelope addressed to the person responsible for handling the complaint or claim and shall be placed by that person in a sealed envelope. immediately brought to the attention of the management of the company and the other members of the investigating committee. It is brought to The model that appears in this protocol is available to employees of the company for the formalisation of the complaint or the claim.
✓ Guarantee of non-retaliation for the whistleblower. Workers will not be penalised for activating the protocol, except in cases of malice or bad faith.
- Admissibility
✓ Analysis preliminary investigation to verify whether the facts denounced fall within the scope of the protocol, upon receipt of the complaint or claim, the investigating committee shall interview the person concerned, and may also interview the person alleged to be the subject of the complaint or both parties, request the intervention of experts, etc. This informal procedure or preliminary phase shall have a maximum duration of seven working days from the receipt of the complaint or claim by the investigating committee.
✓ Communication to the parties on whether or not the proceedings are admissible.
- Internal investigation
✓ Appointment of an impartial investigating committee (normally between 1 and 3 people with a background in equality or HR). The commission will have a duration of four years. The persons appointed to form this investigating committee will comply in a comprehensive way with the impartiality towards the parties concerned This committee shall meet no later than 3 working days from the date of receipt of a complaint, claim or knowledge of inappropriate behaviour, in accordance with the procedure set out in this protocol.
✓ Collection of evidenceinterviews, e-mails, witnesses, documents. The investigating committee shall carry out an investigation, in which it shall decide whether or not there is an infringement or conduct denounced after hearing the persons affected and witnesses proposed, holding meetings or requesting as much documentation as necessary, without prejudice to the provisions on the protection of personal data and confidential documentation. The persons who are requested to do so shall cooperate as diligently as possible.
✓ Statements by both the complainant and the respondentIn the course of the procedure, the person against whom the complaint is made shall be heard first and then the person against whom the complaint is made. Both parties involved may be assisted and accompanied by a person they trust, whether or not he/she is a legal and/or trade union representative of the workers, who shall maintain confidentiality regarding the information to which he/she has access.
✓ Deadline limited and reasonable 30 calendar days.
- Conclusions report
✓ Development of a factual reportThe commission shall draw up a report, assess the evidence and draw conclusions as to whether or not the act exists. At the end of the enquiry, the committee shall draw up a report stating the facts, the
evidence, evidence given and/or gathered, concluding whether, in their opinion, there are indications or not.
✓ Recommendations of measures to be taken: disciplinary, organisational, preventive, etc.
✓ Dispatch of the report to the management or to the competent body.
- Resolution
✓ Company decision on the adoption of corrective measures or penaltiesin accordance with the Workers' Statute or the applicable agreement.
Based on these previous results, REGENERA's management will proceed to:
- File the proceedings in the archives and make a record of them.
- Adopt any measures it deems appropriate on the basis of the suggestions made by the committee investigating the procedure.
✓ Communication to the parties involved, respecting confidentiality.
- Follow-up
✓ Verification that the measures have been implemented and that no retaliation.
✓ Work climate assessment.
✓ Review of the protocol if shortcomings are detected during its application, adopting preventive measures necessary to avoid repetition of the behaviour or conduct, reinforce training and training actions, and awareness-raising.
Reception of reports and complaints.
Admission for processing max. 7 days.
Research phase max. 30 days.
Conclusions report.
Resolution.
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