Ethical Channel

The Internal Reporting Channel or Whistleblowing System of FARMABAN S.A. (hereinafter FARMABAN) has been developed and implemented in accordance with Law 2/2023, of February 20, regulating the protection of individuals who report regulatory violations and combat corruption.

This channel is the means FARMABAN provides for submitting reports on alleged significant breaches or any situation or behavior that may constitute an actual or potential violation of internal or external regulations, including criminal offenses, serious or very serious administrative infractions, or labor violations.

Confidentiality and Reporting Channels

To ensure the confidentiality and, if applicable, anonymity of the whistleblower, FARMABAN offers the following channels:

Report confidentially:

compliance@farmaban.com

Report anonymously:

You may send an anonymous report via postal mail:

To the attention of the Internal Reporting System or Whistleblowing Channel Manager.

Polígono Industrial Santa Anna, Vilella del Claret 6, Sant Fritos de Bages, 08272 Barcelona

Reports must adhere to principles of truthfulness, responsibility, proportionality, and good faith. It is prohibited to submit false information.

External Reporting Channel

In accordance with Article 9.2.b) of Law 2/2023, whistleblowers may also use external channels, such as the Independent Authority for Whistleblower Protection. In Catalonia, this is the Catalan Anti-Fraud Office (OAC).

Basic Data Protection Information

The Privacy Policy of the Channel governs the processing of personal data for managing and handling reports, ensuring confidentiality and protection of whistleblowers.

FARMABAN complies with current data protection laws, processing data based on legal obligations and public interest as per Article 6.1.c) and e) of the GDPR.

Purpose of Data Processing

  • Manage and handle received reports.
  • Investigate reported facts and take appropriate measures.
  • Protect whistleblowers against retaliation.
  • Comply with legal obligations regarding compliance and anti-corruption efforts.

Legal Basis for Processing

The processing is based on the legal obligation derived from Law 2/2023 and public interest when sharing investigation results with competent authorities.

Categories of Personal Data Processed

  • Identification data (name, surname, ID, email, phone, if the whistleblower chooses to identify themselves).
  • Professional data (professional profile).
  • Data related to the reported infringement.
  • Any other information voluntarily provided by the whistleblower.

Data Recipients

  • Public administrations, authorities, and bodies, including courts, as required by applicable regulations.
  • Third-party service providers managing the Channel, acting as data processors.

International Data Transfers

We do not transfer your personal data outside the European Union. In case of international transfers, appropriate technical and organizational measures will be taken to ensure data security.

Automated Decisions and Profiling

No automated individual decisions or profiling are carried out.

Data Retention Period

Personal data will be kept for a maximum of three months unless an investigation requires the opening of a case file, in which case data will be retained until the conclusion of the file. False information will be deleted immediately unless it constitutes a criminal offense, in which case it will be retained until the judicial process is resolved.

Confidentiality and Whistleblower Protection

  • Absolute confidentiality of the whistleblower's identity and provided information, unless legally required to disclose.
  • Protection against retaliation for whistleblowers acting in good faith.
  • Technical and organizational measures to safeguard Channel information.

Principle of Proportionality and Data Minimization

Collected personal data will be limited to what is strictly necessary to process the reports and verify the reported facts. Data will be processed in compliance with data protection regulations, for legitimate and specific purposes related to the investigation, and will not be used for incompatible purposes.

Exercise of Rights

Individuals may exercise their rights of access, rectification, deletion, objection, limitation, and portability at any time and free of charge by submitting a written request to:

  • Postal address: Polígono Industrial Santa Anna, Vilella del Claret s/n, Sant Fritos de Bages, 08272 Barcelona
  • Email: compliance@farmaban.com

Or by submitting a complaint to the Catalan Data Protection Authority (APDCAT).

Privacy Policy Updates

FARMABAN reserves the right to update this Privacy Policy based on regulatory changes or improvements to the Whistleblowing Channel. The latest version will always be available on FARMABAN’s website.