Internal Information System

The Internal Whistleblowing System (IWS) is the system implemented by the FAGOR EDERLAN GROUP to receive and manage information regarding possible irregularities, guaranteeing protection for whistleblowers against reprisals, assuming the communication falls within the established legal framework.

The reference standard is the Whistleblowing Directive (European Directive 1937/2019) whose transposition into Spanish legislation is Law 2/2023 regulating the protection of persons who report regulatory infringements and the fight against corruption(https://www.boe.es/eli/es/l/2023/02/20/2/con).

By means of the internal channels provided, any person related to our organisation, whether work-related or professionally, may inform us of infringements within the material scope of the applicable regulations (infringements of European Union law and, in the case of Spanish companies, criminal offences and serious or very serious administrative offences), as well as breaches of our code of ethics. All of this with full assurance of security and confidentiality and without the possibility of suffering any reprisals, provided that the person has acted in good faith.

The current scope of the FAGOR EDERLAN GROUP’s IWS includes the following group companies:

• FAGOR EDERLAN SCOOP
• EDERTEK SCOOP
• FAGOR EDERLAN SLOVENSKO

The rest of the Group’s companies maintain the ethics channels established for this purpose with our corporate compliance system.

The IWS comprises the following elements:

• Policy, fundamental principles of the Internal Whistleblowing System.
• Specific, independent person in charge of the system, legally appointed by the Governing Board, having named a natural person in charge of receiving and processing information.
• Internal channels for receiving communications Internal channels for receiving communications, designed and enabled to comply with the legal requirements related to security and confidentiality.
• A binding communications management procedure that guarantees the requirements of protection, confidentiality, objectivity and efficiency throughout the process of receiving, processing and resolving communications received.
• And an IT platform that permits both the reporting of cases and the internal management of their subsequent processing. We do this in a secure way, with access to data restricted exclusively to those legally authorised to do so, with a private web area for monitoring and a two-way exchange of information and documentation about the case with the whistleblower.

On entering our internal channel platform, the whistleblower will be taken to a home page where they will be reminded of the general aspects of the channel and where they can read detailed information about our privacy policies regarding whistleblowers and those affected.

From here, it is possible to access the form that allows the whistleblower to provide details about their information, either in written form, as a secure audio recording or, if they wish, by attaching additional documentation. We apply technical measures to protect the whistleblower’s identity, removing metadata from files, distorting the voice and always encrypting any exchange of information.

The whistleblower can report information anonymously or by identifying themself. All personal data will be used exclusively for the intended purposes that can be consulted in the privacy policy and will be processed by authorised personnel, without ever revealing the whistleblower’s identity to either the person to whom the facts reported in the communication refer or third parties.

The form provides an option to request an appointment with the person in charge in order to present or expand on the information personally. This appointment will be arranged within a maximum period of 7 days as from the request through the private web monitoring area which is explained below.

All verbal communications made must be documented, with the consent of the whistleblower, recording them in a secure, lasting, accessible format or by means of a full and accurate transcription of the communication. Without prejudice to their rights under data protection regulations, the whistleblower shall, wherever possible, be given the opportunity to check, rectify and validate the transcript of the conversation by signing it.

Having completed the form, we will confirm the registration of their communication, providing them with a password to access the monitoring area, where they can see how their case is progressing and easily, securely and confidentially exchange information and documentation with the person handling it. It is essential to keep this password safe as, for reasons of confidentiality, it is not possible to retrieve it and should it be lost or forgotten, then all the information will have to be sent to us again.

During the handling of the case, the whistleblower may be asked for additional information via this monitoring area, so it is advisable to access it periodically to check on its status. When the whistleblower is given the access codes to the private monitoring area, they will be offered the choice to provide an e-mail address, the sole purpose of which is to notify them directly of the existence of new information.

The person responsible for the IWS will analyse the information received to determine whether or not it is possible to process it, sending the whistleblower notification as to whether or not their communication has been accepted for processing.

If the communication is accepted for processing, then the internal investigation will begin and within a maximum period of 3 months (extendable to 6 months for complex cases) the whistleblower will be notified of the final decision.

Independent Whistleblower Protection Authority external channel:

Although it is preferable to report potential breaches through the internal channel, should the irregularity being reported fall within the scope of Article 2 of Law 2/2023, i.e. concerning potential criminal offences and serious or very serious administrative offences or breaches of EU law, this can be reported through the external channel of the competent Independent Whistleblower Protection Authority, both directly and after having reported it through our internal channel.