Internal Reporting Channel   Our Internal Reporting Channel is a means of communication that allows employees and other persons to report irregularities or suspected irregularities in Group companies directly, securely, confidentially and anonymously to INDUSTEX and the ISL Group.   Through the Internal Reporting Channel, any person can submit a report/communication about the non-compliance with regulations by companies that are members of the ISL Group and/or their employees/collaborators.  

When should I report?  

The Internal Reporting Channel can be used to report breaches of the Union law as provided for in the Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law (hereinafter referred to as the Whistleblower Protection Directive), criminal offences, severe or extremely severe administrative offences and breaches of labor law in the area of occupational health and safety.   The Internal Reporting Channel is not the appropriate channel for contacting the Personal Data Protection Officer. Nor is it the appropriate channel for customers of the Group’s companies to make suggestions, proposals or submit complaints, for which they can use the contact form.  

How to report a breach?  

It can be done in several ways:  

1. Anonymous report: if you do not wish to identify yourself, you can submit your report/communication:
   • by post to INDUSTEX, S.L. Av. P. Catalans, 34, 8th floor 08950 Esplugues de Llobregat (Barcelona), Spain, for the attention of the Reporting Channel Manager; or
   • by telephone, contacting the Reporting Channel Manager at the following number +34 93 254 71 00.
2. NON-anonymous report: if, on the other hand, you prefer to identify yourself (by name, telephone number, e-mail address or postal address), you may use the following means of communication:
   
   • by post to INDUSTEX, S.L. Av. P. Catalans, 34, 8th floor 08950 Esplugues de Llobregat (Barcelona), Spain, for the attention of the Reporting Channel Manager;
     
   • by e-mail to canal.denuncias@industex.com;
     
   • by telephone, contacting the Reporting Channel Manager at the following number +34 93 254 71 00;
     
   • by requesting a face-to-face meeting with our Reporting Channel Manager on the phone +34 93 254 71 00 or by e-mail at canal.denuncias@industex.com.

What is an external reporting channel?

In addition to this internal ISL Group channel, there is an External Channel for sending your report/communication to the Independent Whistleblower Protection Authority or to the corresponding authorities or regional bodies, either directly or after communication through this internal channel.  

What are the main principles of our Internal Reporting Policy?

1. Prohibition of retaliation: ISL Group undertakes not to take any form of retaliation against any person who has made a report in good faith. This protection extends to persons providing assistance to reporting persons, third persons who are connected with the reporting persons and may suffer retaliation, as well as legal entities owned by the reporting person, among others.
2. Confidentiality and anonymity: The confidentiality of the identity of the reporting person and any third party mentioned in the communication, as well as the protection of personal data during the reporting process and the investigations triggered by the report is an essential principle in the management of the communications received. Communications can be made anonymously.
3. Rights of the concerned persons: The rights to privacy, honour, defence and presumption of innocence of the investigated and concerned persons are guaranteed. The Whistleblower Protection Directive requires that the concerned person be aware that a complaint has been filed against him/her and, therefore, as soon as the initial checks have been carried out and the file has been processed and, in any case, within three (3) months after receipt of the report, the reported person will be informed of the existence of the report and the summary of its content.

What is the procedure once the report has been filed?  

The Internal Reporting Management procedure consists of the following steps:  

• Sending acknowledgement of receipt of the communication to the reporting person, within seven (7) calendar days of receipt.

• Entry of the communication in the ISL Group’s Internal Reporting Register.

• Request for additional information to the reporting person, if necessary.

• Admission or motivated decision on inadmissibility of the report or forwarding the information to the Public Prosecutor’s Office immediately when the reported facts could constitute a crime or reporting to the competent authority.

• Opening of an investigation file. A timeframe to provide feedback shall not exceed three (3) months from the date of the acknowledgment of receipt of the communication. In cases of special complexity that requires an extension of the term, this may be extended up to a maximum of three (3) additional months.

• Termination of the proceedings: dismissal of the complaint, reporting to the Public Prosecutor’s Office or to a competent authority or decision to initiate disciplinary proceedings.