INTERNAL INFORMATION SYSTEM

Below we inform you about the Internal Information System of DFV®GROUP:

In compliance with Law 2/2023, of 20 February, on the protection of persons who report violations of the law and the fight against corruption (hereinafter, the “Law 2/2023”), DFV®GROUP states that it has an Internal Information System, being the company Divasa-Farmavic, S.A. the controller for the processing of personal data in accordance with the provisions of current legislation in this area.

The purpose of this Internal Information System is to provide adequate protection to natural persons who report any of the acts, omissions or infringements provided by Law 2/2023, as well as to strengthen the information culture, the integrity infrastructures of the Group and to promote the culture of communication as a mechanism to prevent and detect threats to the public interest.

The information or communications may be sent to the person Responsible for the Internal Information System (hereinafter, the “RSII”) through the Ethical Channel (internal information channel) of DFV®GROUP, by any of the following means:

  • Email to the address: complianceofficer@divasa-farmavic.com.
  • Postal mail to the address: Carretera de Sant Hipòlit, km. 71, 08503 Gurb, Barcelona (to the attention of RSII).
  • By writing delivered to the RSII.
If requested by the reporting person, the communication may also be presented through a physical meeting with the RSII within seven days of the request.

Verbal communications provided through a physical meeting with the RSII must be documented in one of the following ways, subject to the prior consent of the reporting person:

a) by making a recording of the conversation in a secure, durable and retrievable form, or

b) through a complete and accurate transcript of the conversation prepared by the personnel responsible for handling it.

If the conversation is recorded, the whistleblower shall be warned that the communication shall be recorded and shall be informed of the processing of their personal data in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation or RGPD).

Without prejudice to their rights in accordance with data protection regulation, the whistleblower shall be offered the opportunity to check, rectify and agree the transcript of the conversation by signing it.

The Ethical Channel also allows the presentation and subsequent handling of anonymous communications.

Although the use of the Ethical Channel is preferential, communications may also be sent, where appropriate, to the Independent Whistleblower Protection Authority or to the corresponding authorities or autonomous bodies, to the public prosecutor’s office, to the European Public Prosecutor’s Office or to the competent authority as appropriate.

The Group's Internal Information System complies with the requirements of article 5.2 of Law 2/2023:

a) Allows people to whom Law 2/2023 applies to communicate information, by various means, about the acts, omissions and infringements provided in its article 2.

b) It is operated in a secure manner, so that ensures that communications may be handled effectively within the Group, as well as the confidentiality of the identity of the whistleblower and any third person mentioned in the communication, and of the actions that are developed in its management and handling, as well as data protection, preventing access thereto by non-authorised personnel.

c) It has a Protocol for the Internal Information System, for the use of the Ethical Channel and for the action of the person RSII that establishes guarantees for the protection of whistleblowers:

  • Sending an acknowledgment of receipt of the communication to the whistleblower, within seven calendar days of receipt.
  • Maximum period of three months to provide feedback of the investigative proceedings in the terms provided in article 9 of Law 2/2023.
  • Diligent compliance and custody of an information record book.
  • Possibility of maintaining communication with the whistleblower and requesting further information where necessary.
  • Establishment of the right of the person concerned to be informed of the acts, omissions or infringements attributed to her and to be heard at any time.
  • Guarantee of confidentiality when the communication is sent through reporting channels other than those established or to personnel not responsible for its handling, as well as establishment of the obligation for the person who receives it to promptly forward it to the person RSII.
  • Respect for the presumption of innocence and the honour of the persons concerned.
  • Respect for the provisions on the protection of personal data (Title VI of Law 2/2023).
  • Commitment to forward the information to the public prosecutor's office immediately when the facts could be indicative of a criminal offence.
DFV®GROUP expressly undertakes not to carry out acts constituting retaliation, including threats or attempts of retaliation, against persons who submit a communication made in good faith, and to apply protection measures during the handling of a file regarding persons concerned by possible communication.








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