In accordance with the entry into force of Law 2/2023, dated February 20, regulating the protection of persons who report regulatory violations and the fight against corruption, EUROSOL has established this Internal Information System, hereinafter referred to as SII.
What is the SII?
The SII is the appropriate channel for receiving information about actions or omissions within the scope of application of Law 2/2023, dated February 20, and related to the activities and operations of EUROSOL.
The SII aims to achieve the following objectives:
- Promote a culture of reporting to prevent and detect criminal risks or serious or very serious administrative infractions within EUROSOL.
- Legally protect those who report any infractions covered by the law and who, as a result, might face retaliation within EUROSOL.
What matters can be communicated through the channel?
The matters that can be reported through the SII include:
- Actions or omissions that may constitute serious or very serious criminal or administrative offenses, including any infractions that result in financial harm to the Treasury or Social Security.
- Actions or omissions that may constitute a violation of certain European regulations as listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019, on the protection of persons reporting breaches of Union law, concerning issues such as:
Public procurement.
Financial services, products, and markets, and prevention of money laundering and terrorist financing.
Product safety and compliance.
Transport safety.
Environmental protection.
Protection from radiation and nuclear safety.
Food and feed safety, animal health, and welfare.
Public health.
Consumer protection.
Privacy and personal data protection, and security of network and information systems.
Infractions that affect the European internal market (competition, state aid, tax advantages, corporate tax violations, etc.).
Additionally, breaches or non-compliance with our Code of Ethics and the Criminal Risk Prevention Plan, along with its policies and procedures, may also be reported.
Who can use the channel?
Anyone with employment or professional ties to EUROSOL can report issues, regardless of whether that relationship has ended. This includes, but is not limited to:
1) EUROSOL employees and self-employed workers.
2) Shareholders, members of the governing bodies, management, or supervision, including non-executive members.
3) Volunteers, interns, or trainees, regardless of whether they are paid.
4) Persons involved in selection or pre-contractual negotiation processes who obtained information during those processes.
5) Any person working for or under the supervision and direction of contractors, subcontractors, and suppliers.
Anyone who falls outside of this scope or reports actions or omissions not covered by Law 2/2023 will not be entitled to the protections provided under the law.
It should also be noted that this channel is not intended for complaints, suggestions, or any other circumstances unrelated to the scope of the SII. For these, EUROSOL offers other communication channels.
Finally, any use of the SII in bad faith or the submission of false information through the channel will not be processed, without prejudice to the measures EUROSOL may take.
Key Principles of the Management and Processing Procedure:
EUROSOL has approved the Information Management and Processing Procedure to regulate, in accordance with legal requirements, the responsibilities of the System Manager. The key principles of these procedures are:
- Explicitly prohibit any type of retaliation against those who use the SII within its material and subjective scope.
- Guarantee both the confidentiality and, where applicable, the anonymity of the informant, as well as the confidentiality of the persons affected by the communication.
- Allow the informant to maintain communication with the System Manager and provide additional information unless they have chosen not to follow up.
- Ensure the presumption of innocence, honor, defense, and hearing rights of the affected persons.
- Comply with the regulations regarding personal data processing.
- The System Manager must resolve within three months of receiving the communication, except in complex cases.
Additionally, if desired, individuals may turn to the external information channels provided by the Independent Whistleblower Authority.
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