Novedades Agrícolas, S.A. Complaints channel.

In accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, all companies with more than 50 employees are required to have an internal information channel that allows them to report facts that may involve a serious criminal or administrative offense, or an infringement of EU law.

On the other hand, the regulations include the obligation to make available to interested parties information on the use of all internal information channels, as well as the essential principles of the procedure.

To ensure compliance with the above, we make the following available to you:

NOVEDADES AGRÍCOLAS, S.A., informs:

COMPLAINTS CHANNEL

This whistleblower channel guarantees compliance with the provisions of the aforementioned regulations in accordance with the provisions of articles 7 and 9 of the same.

ANONYMOUS COMMUNICATIONS AND PERSONAL DATA

Communications may be anonymous, with the identification of the informant not being mandatory, and will be answered through the same channel through which they were received, for which purpose it will be necessary to save the tracking code that will be assigned in the message of receipt of the report.

Anonymity shall only be lifted with the express consent of the informant or when it constitutes a necessary and proportionate obligation imposed by Union or national law in the context of an investigation carried out by national authorities or in the context of judicial proceedings, in particular to safeguard the rights of defense of the person concerned.

During the process, therefore, compliance with current data protection legislation will be ensured. (LOPD y RGPD)

USE OF THE WHISTLEBLOWER CHANNEL

When you go to file a complaint, you will notice that you are directed to an on-line tool external to the domain of NOVEDADES AGRÍCOLAS, S.A. The message is transmitted to the tool of an external provider with the objective of guaranteeing total objectivity and transparency in the process of complaint management.

In any case, the external supplier will comply with the instructions established by NOVEDADES AGRÍCOLAS, S.A. and always in accordance with the current legislation on data protection, ensuring compliance with the obligations under Art. 28 of the RGPD.

Therefore, this tool may be used by any employee of NOVEDADES AGRÍCOLAS, S.A. or any other third party who may have knowledge of unethical, fraudulent or illicit conduct committed within our organization.

This whistleblower channel is not the ideal channel for issues related to their conditions of employment or disciplinary matters. In this case, you must follow the policies established in your organization.

COMPLAINTS CHANNEL

This whistleblower channel guarantees compliance with the provisions of the aforementioned regulations in accordance with the provisions of articles 7 and 9 of the same.

ANONYMOUS COMMUNICATIONS AND PERSONAL DATA

During the process, therefore, compliance with current data protection legislation will be ensured. (LOPD y RGPD)

USE OF THE WHISTLEBLOWER CHANNEL

COMPLAINTS CHANNEL

This whistleblower channel guarantees compliance with the provisions of the aforementioned regulations in accordance with the provisions of articles 7 and 9 of the same.

Click here to access to the complaints channel.

BASIC INFORMATION ON PERSONAL DATA PROTECTION.

The party responsible for data processing is NOVEDADES AGRÍCOLAS, S.A. which will process the information collected through the channel in compliance with a legal obligation under Law 2/2023, of February 21, regulating the protection of persons who report regulatory infringements and the fight against corruption, will process the information in order to manage the complaints received through the channel, guaranteeing the confidentiality of the whistleblower’s data, keeping them anonymous without communicating them to third parties unless their identification constitutes a necessary and proportionate obligation imposed by EU or national law in the context of an investigation carried out by the national authorities or in the framework of a judicial process, in which case it must be communicated to the competent authorities in the matter. Your data will be kept for a maximum period of 3 months from the introduction of the data in the channel, but may remain blocked when it is necessary to evidence the operation of the crime prevention model or may be required by the competent authority for the initiation of the corresponding investigation of the facts.

For more information about the treatment of your data or how to exercise your rights, please refer to our Privacy Policy.

Privacy Policy

In compliance with Article 13 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, Article 11 of Organic Law 3/2018 of 5 December, on the Protection of Personal Data and Guarantee of Digital Rights and Article 31 of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, we detail below the information on personal data protection with respect to the processing of data in the Internal Information System:

1. PERSON IN CHARGE OF THE TREATMENT
The person in charge of the treatment is NOVEDADES AGRÍCOLAS, S.A., with NIF A04009650, registered office at Carretera de Mazarrón al Puerto, Km. 2,5, Mazarrón, 30870, Murcia, and telephone (+34) 902400313.

Your personal data will be treated with the strictest confidentiality, only by authorized personnel.

2. ORIGIN OF THE DATA
If you have chosen to identify yourself, your personal data have been obtained through the form you have filled in from the complaints channel set up by NOVAGRIC.

3. PURPOSE OF THE TREATMENT
Your personal data will be processed for the sole purpose of managing and processing the information and investigations of the alleged facts reported, or, where appropriate, to respond to the query raised, as well as to adopt, where appropriate, protective measures and / or prevention of retaliation, all in compliance with the provisions of the Internal Information System Policy and the Protocol for the management of the complaints channel.

4. LEGITIMACY OF THE TREATMENT
The legal basis for the processing of your personal data in the management of the Internal Information System will be that established in art. 6.1.c of the RGPD, insofar as the processing is necessary for compliance with a legal obligation applicable to the data controller in accordance with the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption.

5. CONSERVATION PERIODS
The data processed may be kept in the information system only for the time necessary to decide whether to initiate an investigation into the facts reported.

If it is proven that the information provided or part of it is not truthful, it shall be immediately deleted as soon as such circumstance comes to light, unless such lack of truthfulness may constitute a criminal offense, in which case the information shall be kept for the necessary time during the legal proceedings.
In any case, if three months have elapsed since the receipt of the communication and no investigation proceedings have been initiated, it must be deleted, unless the purpose of the conservation is to leave evidence of the operation of the system. Communications that have not been acted upon may only be recorded in an anonymized form, without the blocking obligation provided for in Article 32 of Organic Law 3/2018 of December 5 being applicable.

In no case will personal data that are not necessary for the knowledge and investigation of the actions or omissions to which Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption, will be processed, proceeding, if necessary, to their immediate deletion. Likewise, any personal data that may have been communicated and that refer to conduct that is not included in the scope of application of said law will be deleted.

If the information received contains personal data included in the special categories of data, it will be immediately deleted, without the registration and processing of such data.

Personal data relating to information received and internal investigations contained in the log-book will only be kept for the period necessary and proportionate to comply with the aforementioned Law. In no case may the data be kept for a period of more than ten years.

6. RECIPIENTS OF THE DATA
We inform you that your identity will be kept confidential in all cases, that it will not be communicated to the persons to whom the facts related or to third parties outside the management and processing of the communication, except when it is necessary for the adoption of corrective measures in the entity or the processing of disciplinary or criminal proceedings, if any, in which case it must be communicated to the competent authorities in the matter.

The personal data processed in the Internal Information System may be communicated to the judicial authority, the Public Prosecutor’s Office, the State Security Forces and Corps, or the competent administrative authority, in the context of an investigation they are carrying out or within the framework of a judicial process. They may also be communicated to the competent state or regional authorities for the protection of the informant.

In the event of outsourcing the management of the internal information system, the information provided through the online channel may be processed by the external third party, as a data processor, in accordance with the provisions of Article 6 of Law 2/2023 of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.

There are no plans for international transfers of data by assignment or commissioning of processing.

7. RIGHTS OF INTERESTED PERSONS
The informants have the right to access their personal data, as well as to obtain the rectification of inaccurate or incomplete personal data, to request the deletion of their personal data and to urge the limitation of the processing, by sending a letter to the postal address above or to the e-mail address [email protected], at any time and free of charge. In addition, you have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es), if you consider that a breach of data protection legislation has been committed with respect to the processing of your personal data.