Ethical Channel

COMMITED TO ETHICS, LEGAL COMPLIANCE AND GOOD PRACTICE

Aldebarán Sistemas makes a confidential communication channel available to employees, clients and suppliers, to allow confidential and, if desired, anonymous reporting of conduct that is considered inappropriate or contrary to the company’s ethical principles described in our Code of Conduct.

The Conduct Code is an extension of our values, because it reflects our commitment and responsibility with ethics, legal compliance and good practices in the exercise of our activity.

COMPLIANCE AND LAW 2/2023

Aldebarán Sistemas has implemented a Whistleblower Channel due to the implementation of the Compliance System in our company and to comply with the requirements of Law 2/2023, of February 20, regulating the protection of people who report regulatory and compliance violations. fight against corruption.

This law adapts the Whistleblowing Directive promulgated by the European Commission, which seeks to improve internal compliance in companies, reduce fraud, infractions and irregularities and guarantee the protection and anonymity of employees who make complaints in companies.

Thus, any ALDEBARÁN worker, collaborator, client, supplier or other interested party of ALDEBARÁN who considers that, for any reason, a practice may be being carried out that:

could involve an action or omission that constitutes a violation of European Union Law,
or that may constitute a serious or very serious criminal or administrative offense; including among these, specifically, those that may imply an economic bankruptcy for the Public Treasury and for Social Security;
as well as conduct contrary to the Criminal Risk Prevention Policy, our Conduct Code or the rest of the regulations within ALDEBARÁN.

You must immediately and directly communicate this to the Compliance Manager through the Whistleblower Channel form that follows below.

FILE A COMPLAINT

COMPLAINT FORM

Personal data are NOT mandatory.

Name and surname

DNI – ID

E-mail addressOnly if you wish to receive notifications about the processing of your com-plaint you must enter a valid e-mail address.

Company

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COMPLAINT TEXT (*Mandatory field):

Please, describe all details about the complaint you wish to make. Try to be as specific as possible, providing the information you consider relevant for a correct resolution.

In any case, you should indicate: time and place of occurrence, possible witnesses, facts that you consider to constitute the action, omission or conduct, identity of the reported person and any other information that may help in the investigation of the facts. You may attach files to complete the information.

Complaint text *

You may attach files to complete the information (maximum size 5 MB).

No file chosen

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Select the type of communication or complaint you wish to make (you can select more than one option):

Action or omission constituting an infringement of European Union Law (regulatory or legal infringement).Action or omission constituting a serious or very serious criminal or administrative infringement, including, specifically, those that may involve a financial loss for the Public Treasury and Spanish National Health System.Conduct, action or omission that constitutes a breach of the values, guidelines for action or standards of conduct contained in the Code of Conduct ALDEBARÁN and other ALDEBARÁN internal regulations, that are mandatory.

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The use of this form for commercial purposes is not authorized.

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BASIC DATA PROTECTION INFORMATION
Responsible:	ALDEBARÁN SISTEMAS (hereinafter, ALDEBARÁN), CIF B99342255 and address at C/ Jerónimo Zurita, 10, entr. izda. 50001 Zaragoza (Spain).
Purpose:	Process, investigate and/or resolve complaints. They will only be processed by those who perform management functions of the Whistleblower Channel in ALDEBARÁN according to the Whistleblower Channel Management Procedure, mainly the Compliance Responsible. Absolute confidentiality and custody are guaranteed under security measures appropriate to the type of data and the risk of the information processed.
Type of data:	Depending on what the used indicates in the text of the complaint or attached files, other types of data may be included.
Legitimization:	Compliance with a legal obligation in accordance with the provisions of Law 2/2023, of 20 February, regulating the protection of persons reporting regulatory infringements and the fight against corruption and the legitimate interest of ALDEBARÁN to comply with the requirements in terms of corporate risk prevention, especially those related to the possible criminal liability of the legal entity, under the Organic Law 3/2018, of 5^th December, on the Protection of Personal Data and guarantee of digital rights.
Recipients:	Your data may be disclosed only in the case of external legal advisors and to the judicial bodies and the State Security Forces and Corps or administrative authority, when necessary.
Conservation period:	Your data will be kept for the time necessary to decide on the appropriateness of initiating an investigation and, where appropriate, while the investigation and resolution complaints filed, and always for a maximum period of 3 months from the filing of the complaint. However, the data may be processed for a longer period outside the Whistleblower Channel System, in the event that the result of the investigation process could lead to the need to exercise the appropriate legal actions and/or could lead to a judicial process.
Exercise of rights	To the physical address of the responsible or by email to aldebaran@aldebaransistemas.com attaching a photocopy of your ID or substitute identification document and indication “Ref. Personal Data Whistleblower Channel ALDEBARÁN” for the processing of these rights by the Privacy Responsible. If you do not see attended the exercise of your rights, you can file a complaint with the Spanish Data Protection Agency (www.agpd.es)
More information	Privacy Policy