Internal communication system

1.¿What is it?

The Internal Information System (SII) is the system implemented by Tafalla Iron Foundry S.Coop. to receive and manage information about possible irregularities, guaranteeing protection against retaliation for informants as long as the communication is within the established legal framework.

The reference standard is the Whistleblowing Directive (European Directive 1937/2019) whose transposition into Spanish law is the Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption.

Through the internal channels provided, any person, whether professionally or professionally related to our organization, may inform us of possible criminal, administrative (serious or very serious) or European Union law violations, as well as breaches of our code of ethics, with full guarantees of security and confidentiality and without suffering any retaliation for doing so, provided they have acted in good faith.

The SII is part of our Compliance System and is composed of the following elements:

• Policy or fundamental principles of the Internal Information System
• System Manager, specific and independent, legally appointed by the Board of Directors and who has appointed a natural person in charge of receiving and processing information.
• An internal communications reception channels, designed and enabled to comply with the legal requirements of security and confidentiality.
• An internal communications management procedure, designed and enabled to comply with the legal requirements of security and confidentiality.
• A compulsory communications management procedure that guarantees the requirements of protection, confidentiality, objectivity and efficiency in the process of receiving, processing and resolving communications received.
• And a computer platform that allows both the reporting of cases and the internal management of the processing. We do this in a secure way and with access to data restricted exclusively to persons legally authorized to do so, having a private web area for the monitoring and bidirectional exchange of information and documentation of the case with the informant.

2. How to inform?

Upon entering our internal channel platform, you will be taken to a home page where you will be reminded of the general aspects of the channel and where you can read detailed information about our privacy policies for reporting and affected persons.

From there, you will be able to access the form that will allow you to provide the details of your information, both in written form, as well as through a secure audio recording and even attaching additional documentation if you wish. We apply technical measures to protect your identity, removing metadata from files, distorting voice and always encrypting any exchange of information.

You can report information anonymously or by identifying yourself. Your personal data will be used exclusively for the intended purposes that you can consult in the privacy policy and will be processed by authorized personnel, without revealing your identity in any case to the person to whom the facts reported in the communication refer or to third parties.

In the form you will have the possibility to request an appointment to be able to expose or expand the information personally with the managing person. This appointment will be arranged within a maximum period of 7 days from your request through the private web tracking area explained below.

The verbal communications made must be documented, with the consent of the informant, by recording them in a secure, durable and accessible format or by complete and accurate transcription of the communication. Without prejudice to his or her rights under data protection regulations, the informant shall, where possible, be given the opportunity to verify, rectify and agree to the transcript of the conversation by signing it.

Once the form has been completed, we will confirm the registration of your communication and you will be provided with an access key to the private follow-up area, where you can, if you wish, find out the progress of your case and communicate and exchange information and documentation with the manager, easily, securely and confidentially. It is essential to keep this password properly since, for confidentiality reasons, it is not possible to recover it and in case of loss or forgetfulness, you will have to send us the information again.

During the management of the case, you may be requested additional information through this private monitoring area, so it is advisable to access periodically to check its status. If you wish, when you provide the access codes to the private monitoring area, you will be offered the possibility of providing an e-mail whose sole purpose is to alert you of the existence of new developments in your case.

The case manager will analyze the information sent to determine whether it is possible to process it or not and will send the informant a notification about the admission or not to process of his/her communication.

If the communication is admitted for processing the internal investigation will begin and within a maximum period of 3 months (extendable, due to the complexity of the case to 6 months) you will be notified of the final resolution.

External channel of the Independent Whistleblower Protection Authority:

Although the preferred channel for reporting possible breaches is the internal one, if the irregularity you wish to report falls within the scope of Article 2 of Law 2/2023, i.e. it concerns possible criminal, serious or very serious administrative or EU law infringements, you can report this through the external channel of the competent Independent Whistleblower Protection Authority both directly and after having reported through our internal channel.