Internal Information System

ROBOT S.A.’s Internal Reporting System serves as the channel for confidentially and effectively reporting any information regarding misconduct committed by ROBOT S.A. or its employees that has come to light in the course of an employment or professional relationship with our organization, in accordance with the provisions of Law 2/2023 of February 20.

The organization has set up its internal reporting system through the following channels:

· In written form:

· Verbally:

  • At the request of the reporting party, the information may also be provided during an in-person meeting with the System Administrator within seven days of the request being submitted.

– In addition to these channels, complaints may be filed with the external reporting channels of the competent authorities, specifically with:

The Independent Whistleblower Protection Authority (A.A.I.) via the following link: Informative Note – Independent Whistleblower Protection Authority

The relevant regional authorities through the external regional channels established for this purpose, in accordance with the terms set forth in Article 8 and related provisions of Law 2/2023.

-Upon receipt of the complaint, the person in charge of the Internal Reporting System shall acknowledge receipt of the complaint to the complainant within 7 days, in cases of complaints filed by name. In any case, the complainant shall be informed of the rights and obligations established by personal data protection regulations.

-The person in charge of the internal reporting system shall issue a reasoned report upholding or dismissing the report filed, providing justification for the decision in all cases. The report will be notified to the whistleblower and the person concerned within a maximum of 3 months from the expiration of the seven-day period following the filing of the report, except in cases of particular complexity that require an extension of the deadline, in which case it may be extended for up to an additional three months.

-During the processing of the complaint, communication and contact with the whistleblower may be maintained, and, if deemed necessary, additional information may be requested from the whistleblower.

-It is ensured that the person affected by the information or complaint is made aware of it, as well as of a brief summary of the facts described. Additionally, they will be informed of their right to submit written statements and of how their personal data will be processed. However, this information may be provided during the hearing if it is determined that providing it beforehand could facilitate the concealment, destruction, or alteration of evidence.

-The person in charge of the Internal Reporting System/Complaints Channel guarantees confidentiality to all those who use the Internal Reporting System/Complaints Channel. Furthermore, they guarantee confidentiality when the report is submitted through reporting channels other than those established or to staff members not responsible for processing it.

-During the processing of the case file, the individuals affected by the report shall have the right to the presumption of innocence, the right to a defense, and the right to access the case file, as well as the same protections established for whistleblowers, with their identity being protected and the confidentiality of the facts and information in the proceedings being guaranteed.

-The processing of personal data resulting from the application of this procedure shall be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, Organic Law 3/2018 of December 5 on the Protection of Personal Data and the Guarantee of Digital Rights, and Organic Law 7/2021 of May 26 on the protection of personal data processed for the purposes of preventing, detecting, investigating, and prosecuting criminal offenses and enforcing criminal sanctions.

-The person responsible for the internal reporting system/whistleblowing channel shall immediately forward the information to the Public Prosecutor’s Office if there is prima facie evidence that the facts constitute a crime, or to the European Public Prosecutor’s Office if the facts affect the financial interests of the European Union.

-The organization guarantees that there will be no retaliation against anyone who brings a possible illegal act to its attention, reports a regulatory violation, cooperates in its investigation, or helps resolve it.

-Individuals who report or disclose violations covered by Article 2 of Law 2/2023 of February 20, or actions or omissions that may constitute a serious or very serious criminal or administrative offense, shall be entitled to protective measures provided that the conditions set forth in Article 35 of the aforementioned law are met. The protective measures are set forth in Article 38 of Law 2/2023 of February 20.

-The complaint or report will be kept on the organization’s premises in accordance with its document archiving and retention policy.

-The organization maintains a record of all complaints received. Complaints will be retained only for as long as necessary and appropriate to comply with the requirements of Law 2/2023 of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption, and in accordance with the provisions of Article 24 and other applicable articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and the Guarantee of Digital Rights.

COMPLAINT FORM  https://portaldenuncias.online/protecmir-robot_s.a.-f5ca38f74