Anyone who has knowledge or suspects of any type of infraction, illegal action, inappropriate behavior, etc. may use, in addition to the internal report to the Corporate Compliance Officer, the following reporting channels enabled:
These channels are both a way of denouncing the breach of legislation and/or internal regulations, as well as of resolving a consultation that may arise in the development of the organization’s activity, ensuring always the confidentiality and the absence of retaliation for the filing of a complaint.
These channels serve both as a means to report any breach of applicable legislation and/or internal regulations, and as a tool to address any queries that may arise in the course of the organization’s activities, ensuring at all times the confidentiality of the matter and the absence of any retaliation for submitting a report.
All individuals who, in good faith, submit communications will be protected against any form of discrimination, retaliation or penalty as a result thereof. False or defamatory reports will be subject to disciplinary sanctions in accordance with internal procedures, applicable agreements and legal regulations.
The confidentiality of the whistleblower’s identity shall be guaranteed. The identity of the whistleblower shall not be disclosed to third parties, nor to the reported person, nor to management, except where such disclosure is necessary to the individuals involved in any subsequent investigation or judicial proceedings initiated as a result of the investigation carried out by the Compliance Management System.
In compliance with applicable Personal Data Protection regulations, it is hereby informed that the data collected through this Ethics Channel will be processed by SYNEOX RAIL S.L., S.A.U. (hereinafter, SYNEOX) and its subsidiaries, for the purpose of managing the corresponding reports and queries, in accordance with the Corporate Compliance Programme and internal regulations.
The processing of data within internal communication channels shall be considered lawful pursuant to Article 6(1)(c) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, Article 8 of Organic Law 3/2018 of 5 December, and Article 11 of Organic Law 7/2021 of 26 May, when, in accordance with Articles 10 and 13 of Law 2/2023 of 20 February, on the protection of persons reporting breaches of regulatory law and combating corruption
The data will be retained for the duration of the investigation and as long as deletion is not requested, and in any case, in compliance with the applicable legal limitation periods. The information received may be shared with the relevant SYNEOX companies where necessary for the purposes of the investigation. The list of SYNEOX companies can be consulted in any official public registry.
Likewise, it is hereby informed that, in any case, the data subject may exercise their rights of access, rectification, erasure, portability, restriction or objection at any time by writing to: Calle Valportillo II, nº 8 bis, 28108 Alcobendas, Madrid (Spain).