What is an Internal Reporting System?

It is the means by which any person in a work and/or professional context can confidentially report or inform on irregular facts or conduct in which any person linked to Torytrans has been directly or indirectly involved and which may constitute a crime and/or serious or very serious administrative offence, or which involves or may involve a violation of the Code of Conduct or the internal regulations of Torytrans.

Please note that other types of requests (e.g. product complaints, job portal, cancellation of personal data, employment enquiries, etc.) cannot be made through this channel.

Please use this channel in a conscious and responsible manner, avoiding abusive use and use in bad faith. It is therefore important that you only transmit information that is reasonably truthful.

How does it work?

There is a form for filing a complaint. An acknowledgement of receipt will be sent within seven days.

If you wish, the report can be made anonymously. In this way, when you fill in the form, your e-mail address or any other information that identifies you will not be shown. It is done through a system that allows absolute confidentiality.

Any evidence, images, videos or documents that support or prove the facts reported may be attached.

Admitted complaints will be studied and investigated within a period of three months, extendable for a further three months, by a Committee made up of internal personnel who will carry out the corresponding investigation with the aim of clarifying the veracity or falsity of the complaint.

The Committee shall ensure the protection of the rights of the complainant (protection against reprisals, confidentiality and/or anonymity), of the accused (right to defence, presumption of innocence and honour) and of personal data.

Objectives of the channel:

• To detect unlawful or irregular conduct.

• To facilitate access to the channel for all our employees, stakeholders and third parties in general.

• To guarantee confidentiality and anonymity.

• Adequately protect the whistleblower as a fundamental part of the organisation's compliance culture.

• Receiving and dealing with reports of irregularities or breaches of regulations committed by employees and/or stakeholders.

• Preserving reputation.

• Build trust with our stakeholders.

• Improve internal processes.

Whistleblower safeguards:

The reports submitted may be anonymous (at the choice of the whistleblower), therefore, it is not necessary to include the identity of the whistleblower, nor the department from which the report originates, nor any information that would allow the whistleblower to be identified.

The confidentiality of both the information communicated and the identity of the whistleblower is guaranteed. Only the persons managing the channel will have access to the report and only they will communicate with the complainant.

No retaliation for good faith whistleblowers.

The whistleblower may exercise his/her rights of access, rectification, opposition, erasure, restriction of processing and portability.

There are also external information channels to which the whistleblower can turn if he/she deems it appropriate. These include the complaints channel of the National Securities Market and Competition Commission (CNMC), SEPBLAC, the Independent Authority for Whistleblower Protection and the Spanish Data Protection Agency (AEPD).