This Code of Ethics sets out the basic concepts of the policies and procedures of García-Munté Energía, S.L. that must be known and fulfilled by all its employees, directors, customers, suppliers and other business partners. It also provides a framework for the company’s ethical standards, summarised in the following general principles applicable to our day-to-day work:
GME’s employees are the essential pillar on which its business is built and therefore their actions mark the future of the company. It is hence extremely important to instil in all our employees the ethical and action principles that must guide them in each of their steps. For this purpose, it is intended to create a working atmosphere characterised by personal responsibility, commitment, honesty, loyalty and respectful interaction with the rest of the staff and with the customers, suppliers or other external business partners with which we could have a relationship.
When preventing and detecting unlawful behaviors, or those opposed to our ethical core values, knowledge is key, and that is why through the following formulary, all our business partners and associates have the opportunity to report any act or transaction in violation with applicable laws or GME’s soft law, of which they have or have had direct or indirect knowledge of or for which there is any indication or certainty that it bears a relation to the aforementioned violations.
All reports filed will be anonymous and there’s no possibility to identify the individual behind it. When filing the report you will be given a reference number that will allow you to check the status of your report, and in case the Ethics Committee were to ask any follow-up questions, you would be able to answer those, in order to avoid the report from being dismissed due to lack of information.
Please keep the reference number and do not share it with anybody. In case of loss of the number it will not be possible to retrieve it. This does not imply the dismissal of the report if all required information was given, just that it will not be possible for you to check its status. If you want to know the status of your report, a new one will need to be filed.
Please note that when reporting any potential cases of harassment, as it’s established in our Protocol for the Prevention of Harassment, anonymous reports are not allowed, and the individual will have to identify him/herself in the body of the report. Not complying with the aforementioned will determine the dismissal of the report.
Please do as well remember we have available a direct line to our Compliance and Ethics Committee for all our business partners and associates: firstname.lastname@example.org.
Pursuant to the provisions in the data protection regulations in force and specifically 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, and the Spanish Act 3 of 5 December 2018 on protection of personal data and the guarantee of digital rights, we hereby inform you that GARCÍA-MUNTÉ ENERGÍA, S.L., (hereinafter referred to as “GME”), with registered office at Calle La Selva, 12, 08820, El Prat de Llobregat (Barcelona), will process the personal data and any information you provide in the available form through the whistleblowing channel for the sole and exclusive purpose of processing and managing your reports.
In this respect, the data will be processed to collect, store, manage and process the reports received through the available whistleblowing channel in order to detect and investigate any irregularity in the company related to infringements of the applicable legal and internal regulations.
The personal data will be processed to fulfil any applicable legal obligations and according to GME’s legitimate and public interest in investigating the reports received.
The data will also be included in GME’s Data Protection System and will only be processed for the indispensable time required in order to decide on whether or not to launch an investigation of the facts reported. In any case, the maximum term will be three (3) months, counted from the date the report is recorded, unless the investigation is still ongoing. The personal data related to reports that are not subject to investigation will be immediately erased.
Only GME’s authorised staff who perform internal control and compliance duties and the data processors that are possibly appointed for such purpose will be allowed access to GME’s Data Protection System.
We also inform you that you can exercise your rights to access, rectify, erase, oppose and restrict the processing or portability of the data by sending a request to the aforementioned address, attaching a copy of your National Identity Card (DNI) or passport, or else you can send an email to email@example.com.
This Company has appointed a Data Protection Officer (DPD). You can contact him by sending an email to firstname.lastname@example.org.
Likewise, by submitting the form, you declare that you have been informed of your right to file a claim with the Control Authority, the Spanish Data Protection Agency.”