In line with best market practices, Ibexia Cox Energy Development, S.L. (“Ibox Energy”) has established, both internally and for the companies in its group, a communications channel that acts as an important resource for objectively and properly reporting, identifying and investigating any behaviour, event or situation that could constitute a violation of the principles and rules set out in the Ibox Energy Corporate Code of Ethics or any legal provision. This particularly refers to behaviour, events or situations that constitute or may be presumed to constitute offences within the framework of Ibox Energy’s activities or those of the companies in its group (the“Whistleblowing Hotline”).
The Whistleblowing Hotline is available to all the employees, associates, managers and directors of Ibox Energy and the third parties with which it maintains commercial or professional relations, as a confidential channel for reporting any unlawful behaviour or any irregularity or infringement detected in relation to the Corporate Code of Ethics and the legislation in force, as well as for consulting the company about any issue that may arise regarding the interpretation or application of the Code and its implementing regulations.
The following email address is provided for this purpose: firstname.lastname@example.org
This address is directly and exclusively accessed by Ibox Energy’s head of regulatory compliance. If, after making the appropriate enquiries, the head of compliance considers that the behaviour, events or situations reported via the Whistleblowing Hotline may involve, or may at least be presumed to involve, an offence, irregularity or infringement under the terms of the Corporate Code of Ethics and the legislation in force (particularly criminal law), he or she will inform the Board of Directors and, where applicable, propose the relevant disciplinary measures or other actions to be taken. In all other cases, these measures will be agreed between the heads of regulatory compliance and human resources.
Taking account of Directive 2012/1937, on the protection of persons who report corruption, which protects and supports people who report unlawful conduct and infringements (known internationally as “whistleblowers”), the following user regulations have been established to ensure both rigour and confidentiality when processing communications via the Whistleblowing Hotline:
The Whistleblowing Hotline may only be used to report behaviour, events or situations that are irregular or presumed to be irregular under the terms of the principles and standards of the Corporate Code of Ethics or the legislation in force, particularly when such behaviour, events or situations constitute an offence, in relation to the activities of Ibox Energy and its internal relations or the activities of the third parties with which Ibox Energy maintains commercial, professional or institutional relations, though not in relation to any other areas or people’s private lives.
Reports may be made anonymously via the Whistleblowing Hotline .
Each report must include at least the following information :
The identity of the person or persons observed to have acted irregularly.
A description and details of the behaviour, events or situations of which this irregularity consists, with specific details, where possible, of the way in which Ibox Energy’s Corporate Code of Ethics or the relevant legislation has been breached.
Any documentation that supports or provides evidence of the behaviour, events or situations in question, wherever possible.
Any personal information that results from these reports will be protected using the security measures provided for in the legislation governing the protection of personal data. .
Both the person submitting the report, where they have not remained anonymous, and the affected party or parties, will be informed, as far as the procedural circumstances allow, regarding their rights of access, rectification, elimination, objection, limitation of processing and portability, in compliance with the applicable personal data protection regulations .
Any personal data will be deleted ex officio when they have ceased to be necessary or relevant for this purpose and, in all cases, within a maximum of two months following the completion of the internal procedure or the relevant court proceedings. .
Ibox Energy guarantees that no-one who uses the Whistleblowing Hotline in good faith will be subject to reprisals, discrimination or disciplinary sanction of any kind, when:
They inform Ibox Energy ofthe aforementioned behaviour, events or situations that constitute, or may be presumed to constitute, a violation of the rules governing ethics and compliance.
The action reported is against the law, including any offence.
They cooperate in the investigation or resolution of the behaviour, events or situations reported.
This guarantee will not extend to those who use the Whistleblowing Hotline in bad faith with the aim of spreading information that is false or harmful to a third party.
Any person who is included within the applicable scope of the Corporate Code of Ethics and becomes aware of a violation of the Code, or of any of Ibox Energy’s internal standards, policies or procedures, or of the legislation in force, is obliged to report the behaviour in question in the proper manner using the Whistleblowing Hotline.