Whistleblowing Channel
The Whistleblowing Channel (hereinafter, the "Channel") is a means to report actions or omissions that may constitute criminal or administrative offenses serious or very serious occurring within the environment of Sales Layer Tech, S.L. (hereinafter, "Sales Layer").
It is implemented in compliance with Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and fight against corruption (hereinafter, "Law 2/2023"). With the implementation of the Channel, Sales Layer also seeks to strengthen the culture of information and promote communication as a mechanism to prevent and detect violations that may harm the company and threaten public interest.
The Channel is available to all persons who, within the framework of their employment, professional, or contractual relationship with Sales Layer including employees, interns, shareholders, contractors, and subcontractors, among others regardless of whether the relationship is current, has ended, or has not yet begun, detect violations that must be reported to Sales Layer (hereinafter, "Whistleblowers").
Through the Channel, Whistleblowers may confidentially and, where appropriate, anonymously report information related to actions or omissions within Sales Layer that may constitute serious or very serious criminal or administrative offenses (hereinafter, "Communication"). Communications whose content does not report such legal violations and/or contain commercial, personal, or labor complaints will be dismissed and excluded from the specific protection of this system.
An acknowledgment of receipt of the Communication will be sent to the Whistleblower within seven (7) calendar days of its receipt. Sales Layer will carry out the necessary investigative actions, which will not extend beyond three (3) months from the receipt of the Communication, except in cases of special complexity where this period may be extended by an additional three (3) months.
The Communications and investigative actions will be managed by responsible personnel designated by Sales Layer, respecting the principle of presumption of innocence and the honor of the affected individuals.
The confidentiality and, where appropriate, the anonymity of the Whistleblowers, the persons accused of violations, and those mentioned in the Communication will be respected.
The confidential nature of the Communications shall maintained even when they are transmitted through means other than those provided by Sales Layer. i.e., the Channel or the Channel Manager. Any member of Sales Layer who receives such information without being authorized must immediately report it to the Channel Manager, ensuring its confidentiality. Failure to do so constitutes a very serious offense, in accordance with the aforementioned Law 2/2023.
Persons accused of offences have the right to know the actions or omissions attributed to them and to be heard at any time. All of this will be carried out in a timely and appropriate manner to ensure the proper outcome of the investigation.
There will be communication between the staff conducting the investigative actions and the Whistleblower whenever relevant, and additional information may be requested from the Whistleblower if necessary.
Providing information to the Channel is not a mandatory prerequisite. Whistleblowers may, if deemed necessary, file the relevant complaints with the competent administrative and judicial authorities, as indicated in the applicable regulations.
If a Communication contains actions or omissions that may directly or indirectly constitute a crime, they will be referred to the Ministerio Fiscal, if the facts described in the Communication affect the financial interests of the European Union, they will be immediately referred to the Fiscalía Europea.
The Channel is the preferred means for submitting Communications; however, Whistleblowers also have access to external channels (such as the Independent Authority for Whistleblower Protection).
By using the Channel, the Whistleblower agrees to:
If the Whistleblower fails to comply with these obligations, makes false Communications, or acts in bad faith, they may be sanctioned as provided in Law 2/2023 and may incur criminal, civil, and administrative liability in accordance with applicable regulations.
Data Controller: Sales Layer Tech, S.L.
Purpose of Processing: To manage, investigate, and respond to Communications received through
the Channel, in compliance with Law 2/2023, of February 20, regulating the protection of persons
who report regulatory violations and fight against corruption.
Legal Basis: The legal basis for processing is compliance with a legal obligation.
Recipients: Communication to third parties is not foreseen unless it is essential for the development
and execution of the purposes of the processing, such as the Ministerio Fiscal or competent
administrative authorities.
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