Whistleblower Channel – ALDEBARAN SISTEMAS

ALDEBARÁN is fully committed to the highest ethical and Compliance standards in all its relationships and activities.

To ensure the maintenance of the Criminal Risk Management System, ALDEBARÁN Management Body has appointed and empowered a Compliance Responsible (CO), whose functions include the management of the Whistleblower Channel in accordance with C_PG007 Whistleblower Channel Management Procedure, which we invite you to consult.

ALDEBARÁN makes available to its members and any interested party, its Whistleblower Channel to report confidentially and even anonymously, any suspicious or knowledge of conduct, actions or omissions committed by a member of ALDEBARÁN in the exercise of their functions:

constitute infringements of European Union Law,
may constitute a serious or very serious administrative offence, including, specifically, those that may involve an economic loss for the Public Treasury and Spanish National Health System,
constitute breaches of the values, guidelines for action or standards of values, guidelines for action of conduct contained in the Code of Conduct of ALDEBARÁN and other internal regulations of ALDEBARÁN that is mandatory.

The aforementioned communications must be made using the following form.

The reporting person may also request a face-to-face meeting with the Compliance responsible (CO) through said from for the purpose of making a communication or complaint of the kind described above. In such case, the Compliance Responsible shall arrange such meeting within a maximum of seven (7) working days. In the event of a face-to-face meeting, and after obtaining the express and informed consent of the complainant regarding the processing of their personal data, the conversation held shall be documented in one of the following ways:

Recording of the conversation in a secure, durable and accessible format.
Complete and accurate transcription of the conversation. In this case, the complainant shall be given the opportunity to verify, rectify and agree with the transcript of the conversation by signing it.

Without constituting the preferred form for the submission of complaints and as an alternative to this internal ALDEBARÁN Whistleblower Channel, complaints may be submitted through external complaints channel to the Independent Authority for Whistleblower protection, to the competent administrative authorities, where appropriate, or to the institutions, bodies, offices and agencies of the European Union.

All complaints received will be entered into complaints register and each complaint will be assigned a unique reference number by which it can be identified throughout its processing.

All reports may be anonymous, for example, the identification of the person making the complaint is not mandatory but optional.

It is reported that only in the event that the informant or complainant provides an address, email or safe place to receive notifications, they will be noticed of the acknowledgement of receipt with a reference number of the complaint; ALDEBARÁN may request additional information if necessary and keep you informed of the admission or not to process and the corresponding resolution.

Complaints will be evaluated, investigated and resolved within a period not exceeding three (3) months from receipt of the complaint.

ALDEBARÁN states that the Whistleblower Channel complies with the following principles and offers the following guarantees, the specific development of which can be consulted in the Whistleblower Channel Management Procedure :

Maximum confidentiality.
Guarantee of the right to defence, presumption of innocence and the right to honour.
Guarantee of the principle of evidence and contradiction.
Management of conflicts of interest.
Prohibition of reprisals, including threats and attempts of reprisals.
Protection of personal data.

FILE A COMPLAINT

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

……………………………………………………………………………………..

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

……………………………………………………………………………………..

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.

……………………………………………………………………………………..

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

……………………………………………………………………………………..

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