TERMS AND CONDITIONS OF THE ETHICAL CHANNEL
1. Acceptance of Terms and Conditions
This ethical channel is made available to the employees, executives, shareholders, clients, and suppliers of the MADME Group.
2. Service Description. Users Authorized by MADME Group
MADME Group uses this platform to provide access to its clients, suppliers, employees, or executives/shareholders. To use this ethical channel, the Whistleblower must obtain access through the provided MADME Group link and have the necessary equipment to connect to the network.
The Whistleblower has access to a complaint registration form where they must enter the required data, some of which are mandatory (marked with an asterisk, including the type of complaint, type of whistleblower, reported incidents, description of incidents, ID, name and surname, and contact email), and others are voluntary.
Once all mandatory fields are completed, the form will prompt confirmation of having read and accepted the service conditions. After loading the data in the Report, the Whistleblower must press the "Submit Report" button.
Once those conditions are accepted and the button is pressed, the report will be sent, and a code will be assigned, along with the contact email of the person in charge of handling the report at MADME Group.
The existence of the report will be simultaneously received in the email addresses specified by MADME Group, usually corresponding to those responsible for handling reports in the organization (who should be part of their Compliance Committee or Compliance Officer) and the legal or technical advisor specializing in compliance at MADME Group.
Upon receiving the notification of the report's existence, the MADME Group treatment manager and their compliance advisor can access the platform with their private keys, where they will download the content of the report and attached documents, with confirmation data being recorded. From that moment, MADME Group must handle the report according to the established protocol for such situations. A protocol outline is included at the end of this document.
3. Obligations of the Whistleblower for Service Use
The Whistleblower undertakes to provide information in good faith, correct, and complete about the reported incidents. If they provide information in bad faith, intentionally inaccurate, or incomplete, MADME Group may take disciplinary and/or legal measures deemed appropriate.
4. Confidentiality and Privacy Policy of Data Supplied through the Platform
Only individuals with the corresponding keys at MADME Group, usually designated as the person in charge of handling such reports (typically part of the compliance or normative compliance department) and the compliance specialist advisor authorized by the company for this purpose, will access the content of your report and its attached documents.
The handling of reports is exclusively the responsibility of MADME Group, which is obligated to maintain strict confidentiality regarding the data disclosed through this system. The Whistleblower accepts that MADME Group may retain and/or disclose the supplied data if required by law and/or any public authority.
Due to the nature of this service, it is recognized that the data provided through it may contain private information about reported individuals, which will have been provided and transmitted by the Whistleblower.
Therefore, MADME Group assumes no responsibility for the violation of privacy and/or confidentiality laws that the actions of the Whistleblower may generate, especially those stipulated in the Data Protection Law (LOPD).
PROTOCOL OUTLINE OF PROCEDURES
