Ethics Code and Channel
At NAPAU SISTEMAS, S.L., we firmly believe in the importance of fostering a safe, ethical environment based on equality and trust for all our employees, customers, and partners in general. For this reason, we are guided by an Ethics Code, which can be downloaded here.
We have also implemented an Ethics Channel that allows anyone to report potential misconduct or ethical breaches they have identified within our organisation. A channel through which any potential breach or irregularity within the organisation can be reported, as described in Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption.
WHAT MATTERS CAN BE REPORTED?
You may report through the Ethics Channel any matters you believe may constitute a breach of legal regulations, the Ethics Code, or any applicable internal policy. In all these cases, the Ethics Channel allows reports to be submitted either identified or anonymously, if the reporting person so wishes:
- Conduct related to fraud and corruption.
- Conduct related to workplace safety, health, and hygiene.
- Conduct related to information security and data protection.
- Anti-competitive practices.
- Conduct contrary to human rights or harm to the environment.
- Abuse of authority, unfair treatment, or inappropriate behaviour not related to sexual harassment or discriminatory harassment.
- Other potential serious or very serious criminal or administrative offences.
In cases of workplace harassment, sexual harassment, or harassment on grounds of sex, discrimination or gender-based violence, the report must be submitted with identification and cannot be anonymous. This is due to the provisions of Law 2/2023 on whistleblower protection, and the specific regulations on equality and the prevention of harassment.
These situations must be reported exclusively via the dedicated email address:
canaldenunciasnps@npsseguridad.com
ESSENTIAL PRINCIPLES OF THE MANAGEMENT PROCEDURE:
Confidentiality: We understand that confidentiality is essential to encourage people to submit reports through the ethics channel. We guarantee absolute confidentiality throughout the process and protect the identity of the reporting person to the extent permitted by law.
Impartial investigation process: Once a report is submitted, our team of expert channel managers will thoroughly investigate the matter objectively and diligently, in accordance with internal policies and applicable legislation. Throughout the process, the rights of those involved will be respected, in particular the presumption of innocence.
Protection against retaliation: We do not tolerate any form of retaliation against reporting persons acting in good faith. We are committed to safeguarding the rights and integrity of those who dare to report any irregularity. We will take appropriate disciplinary action against any individual who retaliates against a reporting person.
Diligence: The channel managers will handle the information reported to them diligently. In any case, the necessary decision will be adopted within a maximum period of three months, except in cases of particular complexity that require an extension, in which case it may be extended by up to a further three additional months.
Resolution and follow-up: Once the investigation is concluded, we will take the necessary actions to address the identified issue and, where possible, take corrective measures to prevent future irregularities. In addition, we undertake to keep the reporting person informed of the progress and resolution of their report, whenever possible and permitted by law.
HOW TO SUBMIT A REPORT?
There are 2 options.
Via the Co-Resol application:
Step 1. Download the co-resol app and accept notifications. It is free and available on the App Store and Google Play.
Step 2. Click the “make a click” button and enter the code GCABELLO.
Step 3. Select the channel button: Ethics Channel – NPS
Step 4. Write your message or leave a voice note, being as specific as possible. You may attach both images and documentation.
Step 5. Identify yourself or select the anonymous option. In either case, you must accept the Privacy Policy.
Step 6. Once you have completed these steps, you will receive a message acknowledging receipt of your report.
Step 7. Follow-up communication regarding the report will be carried out via a secure chat (you can access it from the chat button on the app’s home screen) until it is closed.
Via a web page:
You can access it via this link: https://canalco-resol.com
Step 1. Click the “Make a click” button and enter the code GCABELLO.
Step 2. Select the channel button: Ethics Channel – NPS
Step 3. Write your message or leave a voice note, being as specific as possible. You may attach both images and documentation.
Step 4. Identify yourself or select the anonymous option. In either case, you must accept the Privacy Policy.
Step 5. In this case, together with the acknowledgement of receipt, a unique Identifier code and password will appear on screen, which you must keep in order to maintain communication, via a secure chat, regarding the status of your report.
Step 6. Each time you want to check whether you have a new message in the chat or wish to provide more information, you must go to the home link https://canalco-resol.com, click the “Access a previous report” button, and enter the code GCABELLO, as well as the Identifier and password you saved.
Important:
This Ethics Channel is not an emergency service. This channel must not be used to report situations involving an immediate threat. If you need assistance in such a situation, please contact your local authorities and use the channels defined for that purpose.
You may consult the Channel’s General Policy, which sets out the main aspects of this reporting system here.