What is Whistleblowing Channel?

Whistleblowing Channel is a confidential reporting channel to register potentially irregular activities and behaviors that may involve a breach of the Code of Conduct and/or possible commission of a criminal offence.

Who manages the communications?

The Whistleblowing Channel is managed by internal and external specialists, in according with the Code of Conduct.

Are the complaints confidentially?

In accordance with the provisions of Law 2/2023 of 20th February, the identity of the whistleblower is not disclosed to the persons to whom the facts refer or to third parties. The identity of the whistleblower may only be disclosed to the areas in charge of the investigation provided that this information is essential for the course of the investigation and that the prior consent of the informant has been obtained. CRUZBER guarantees maximum confidentiality at all times.

How are personal data treated?

Data to the complainant and the accused, as well as other persons/witnesses involved will be treated in accordance with the Law 2/2023, of 20th February. Data of the accused, the complainant and those involved may be communicated to the Police, Courts and Tribunals if the reported facts constitute a possible crime. In any case, all personal data will be kept in internal files during legal requirement or investigation, after which they will be deleted.

What is the process for a complaint?

Any person can initiate the complaint process through the form at https://company.cruz-products.com/en/complaint-channel/

It is important to complete all required fields. The complaint might be rejected by lack of information. When the complaint is registered, a reference code is assigned to it. It is very important that you keep this reference code, because the reference code and the chosen password, it will give you access to check the status of the complaint.

After the complaint has been received, the Compliance Department will analyze and evaluate the complaint, admitting it or not, according to the criteria specified in CRUZBER’s Code of Conduct.

Admitted complaints were investigated by internal personal, carrying out all those investigations, inquiries and data collection to solve the facts.

When the investigation is finished, the Compliance Department will public a report explaining the case, the investigation and its resolution. If the facts constitute a crime, the report and personal data will be sent to the corresponding judicial authorities.

The maximum resolution time of case is 90 days from the day following the registration in the Whistleblower Channel.

Which are the grounds for non-admissibility?

The complaint must correspond to irregularities of CRUZBER’s Code of Conduct, or constitute an unlawful act or an act contrary to applicable regulations. Complaints that do not contain all the required information, do not constitute a breach or non-compliance or do not provide sufficient clarity or detail to determine whether there is a potential irregularity will not be admitted for processing.

What is the status of the complaint?

The status of the complaint can be consulted at any time by entering the reference number and the password chosen at the time of registering the complaint. The status of the complaint can be:

• Pending if the complaint has not yet been read by the compliance department.
• Admitted if the complaint is being investigated.
• Unadmitted if the complaint does not meet the criteria for admission. The reason for inadmissibility will be reflected in the “Comments” box.
• Resolved in case of admitted complaints: actions taken after the resolution of the case will be reflected in the “Comments” box.

What actions are taken after resolution?

The Compliance Department may take the following actions after the resolution of the case:

• Close the file if no facts of non-compliance with the Code of Conduct are observed or due to lack of evidence.
• Apply internal corrective measures.
• Bring the reported fact to the authorities.

What happens if a false and/or bad faith communication is made?

Communications made by impersonating the identity of the informant or detailing facts that are known to be uncertain or involve persons who have had no relation to such facts, even if they are true, shall be considered to be made in bad faith. The presentation of a false and/or bad faith communication will imply the adoption of the corresponding legal and/or disciplinary measures against the person who has made the communication.

What are the rights of people affected by a communication?

The person affected by a communication are the right to know the details of the complaint in case it is admitted. The complainant’s personal data will not be disclosed. In either case, CRUZBER will respect for the presumption of innocence and honor, as well as the right of defense, the right to be heard at any time and the preservation of their identity and the confidentiality.