Whistleblowing policy

Updated: 01/04/2026 19:06

1. Introduction

Inappropriate conduct by an employee or collaborator can significantly affect the perception and reputation of the company. For this reason, at Sancal we actively strive to prevent and avoid any situation that could compromise our values.

It is imperative that all employees and collaborators acting on behalf of Sancal do so in accordance with applicable legislation, our Code of Ethics, and the internal policies in place. The cooperation of all staff in detecting irregular conduct is fundamental to our preventive efforts. In line with current legal provisions, particularly Law 2/2023 of 20 February, regulating the protection of persons who report regulatory infringements and combating corruption, the Criminal Code, and other relevant regulations, the need for preventive systems that allow for the identification and management of potential legal risks within the company is reinforced. In this regard, the ‘Whistleblowing Channel’, in harmony with our ethical and compliance principles, offers Sancal members the ability to report potential risks or breaches.

This policy details the operation of Sancal’s Whistleblowing Channel, who can submit reports, in which situations, and the procedures to follow once a report is received. All of this, of course, guaranteeing maximum confidentiality, a fundamental pillar of this Channel. It is crucial that all members of Sancal are aware of this tool, which undoubtedly contributes greatly to preserving our image, prestige and reputation, protecting them collectively.

2. Users of the Whistleblowing Channel

The Whistleblowing Channel is available to all professionals involved in our operations, including employees, managers, external collaborators, as well as clients and suppliers who are aware of any irregularity affecting the company.

It also extends to informants who communicate information about infringements obtained within the framework of an already completed employment or professional relationship, volunteers, interns, employees in training periods, and individuals participating in selection processes.

Who should use the Whistleblowing Channel?

All employees, managers (any individual providing managerial services with powers of representation or organisation, regardless of their contractual relationship), members of the Board of Directors, external collaborators, and all parties related to Sancal have the responsibility to report any irregularity within the defined scope, without fear of retaliation and with full confidentiality.

Who can be reported through the Whistleblowing Channel?

Any employee, manager, member of the Board of Directors, or external collaborator subject to Sancal’s authority who has committed any of the conduct described in the objective scope established in this document may be the subject of a report.

3. Reportable Conduct

The Whistleblowing Channel covers conduct listed in Annex I, including those classified as criminal offences under the Criminal Code or other special laws, which may give rise to criminal liability for Sancal Diseño S.L. These conduct include, among others:

Public Corruption Misleading Advertising Business Corruption
Money Laundering / Terrorism Financing Fraud Smuggling
Punishable Insolvency Crimes Involving Risks Caused by Explosives and Other Agents Obstruction of Enforcement
Securities Crimes Computer Damage Crimes Against the Rights of Foreign Nationals
Crimes Relating to Intellectual and Industrial Property Crimes Against Public Health Disclosure of Trade Secrets
Price Fixing Crimes Against Personal and Family Privacy Fraudulent Invoicing
Tax Fraud Counterfeiting of Currency and Stamped Documents Breach of Accounting Obligations
Bid and Auction Rigging Social Security Fraud Crimes Against Workers’ Rights
Grant Fraud / Fraud Against the EU General Budget Refusal to Cooperate with Inspections Crimes Against Natural Resources and the Environment

—

In addition, any conduct contrary to the principles and standards of conduct established in Sancal’s Code of Ethics may also be reported through this Whistleblowing Channel.

4. Means for Receiving Reports

In principle, all reports that are to be filed must be submitted through the channels designated by Sancal.

Reports must be submitted in writing and addressed to the Corporate Ethics Unit of Sancal Diseño S.L through the following means:

Without prejudice to the above channels, the informant may also contact the Independent Authority for the Protection of the Informant (A.A.I.) or the corresponding regional authorities or bodies, as an external whistleblowing channel.

It is essential to note that only those reports submitted through the means indicated above will be considered received and admitted for processing. Those that do not comply with these channels will be deleted and destroyed.

5. Whistleblower Protection Measures

Prohibition of Retaliation

Whistleblowers who file reports in good faith are protected against any form of retaliation, discrimination, or penalisation arising from their report. Sancal will take disciplinary action against any retaliation directed at a good-faith whistleblower, considering actions such as dismissal, unjustified salary reduction, transfer to another workplace, or assignment of lower functions and responsibilities.

In the event that a whistleblower perceives retaliation solely for having filed a report, they may report it to the Corporate Ethics Unit of Sancal Diseño S.L, which will study the case and take preventive or corrective measures as appropriate.

It is important to note that the prohibition of retaliation shall not prevent the adoption of disciplinary measures in the event that an internal investigation demonstrates that the report was false and that the whistleblower acted in bad faith, knowingly aware of the falsity of the facts.

Confidentiality of the Whistleblower’s Identity

Sancal guarantees maximum confidentiality regarding the identity of the whistleblower. The right of access by the reported party, in accordance with the Organic Law on Data Protection, shall not imply access to the personal data of the whistleblower, thus preserving their identity. Sancal commits to not disclosing the identity of the whistleblower, unless judicially determined otherwise.

The principle of confidentiality is fundamental to the operation of Sancal’s Whistleblowing Channel, serving as a pillar to ensure that whistleblowers are protected and that the filing of reports is not discouraged.

Measures in Cases of Conflict of Interest at Sancal Diseño S.L

In situations where reports arise related to the responsibilities of the Corporate Ethics Unit of Sancal Diseño S.L, or where such reports may potentially give rise to a conflict of interest for any of these parties, specific measures are established to ensure impartiality and proper management of such cases.

A conflict of interest shall be deemed to exist when the personal interests of a member may affect their capacity to handle reports with objectivity and neutrality. This conflict may arise when reports are related to the Corporate Ethics Unit. Likewise, a conflict may be identified if the facts affect persons with family ties (up to and including the third degree) or business interests, such as holding shares or interests exceeding 10% in the same company.

Consequently, if a whistleblower suspects the possibility of a conflict of interest with the Corporate Ethics Unit, they may submit the report directly to the Secretary of the Board of Directors if the conflict affects any member of that committee. In such cases, and after verifying the existence of the conflict of interest, an external expert shall be appointed to manage and handle the investigation of the report.

6. Report Handling Procedure at Sancal Diseño S.L

Receipt of Reports

Once the information has been submitted through the digital platform https://app.canaldedenunciassoftware.com/sancal-diseno-s-l/

Tracking Code: The system will automatically generate a Tracking Code (report ID). This code is the only link between the informant and SANCAL, guaranteeing technical anonymity.

Acknowledgement of Receipt: The system itself issues an immediate digital acknowledgement of receipt. SANCAL will confirm receipt of the report within a maximum period of seven (7) calendar days.

Report Enquiry: The informant must periodically access the channel website and enter their code to:

  • View the status of their report (Pending, In Progress, Resolved).
  • Respond to requests for additional information from the investigator.
  • Consult the final resolution of the case.

IMPORTANT: SANCAL will not send emails or make telephone calls to the informant in order to protect their identity. Communication will be conducted exclusively “within” the platform using the aforementioned code.

Except in situations covered by the conflict of interest provisions, all reports will be received by the Corporate Ethics Unit of Sancal Diseño. This unit will initially analyse the reported facts and verify their correspondence with the designated form. Subsequently, it will determine whether to proceed with the investigation or dismiss the report, with a maximum period of five (5) working days from receipt to make this decision.

a) Dismissal of the report: If the report does not meet the established formal requirements, or if it is evident that the reported facts do not constitute an infringement within the scope of the Whistleblowing Channel, the Corporate Ethics Unit will dismiss the report. Within no more than two (2) working days, this decision will be notified. In justified circumstances, the Board of Directors may override this decision and request the admission of the report, with a maximum period of ten (10) working days from the receipt of notification by its secretary.

b) Admission of the report and commencement of investigation: If the report meets the formal requirements and there are indications that the reported facts occurred within the scope of the Whistleblowing Channel, the Corporate Ethics Unit will proceed with the admission of the report and initiate the investigation phase.

Once this stage is concluded, the Corporate Ethics Unit will notify the whistleblower of the decision taken within a maximum period of five (5) working days. In any event, the maximum period for responding to investigative actions shall not exceed three months from the receipt of the report (or seven days after submission if no acknowledgement of receipt was provided), except in cases of particular complexity requiring an extension of up to a further three additional months.

Investigation of Reports

Once the report is admitted for processing, the Corporate Ethics Unit of Sancal Diseño will commence the relevant investigations to verify the accuracy of the reported facts. To this end, the information and documentation necessary to clarify the events may be requested.

Sancal Diseño staff will be obliged to cooperate with investigations whenever required to do so.

In situations where the nature of the facts indicates investigative complexity, the specialised assistance of an external expert may be sought. This collaboration will be coordinated with the Corporate Ethics Unit.

Proposed Resolution

Upon conclusion of the investigation, two crucial steps will be taken:

  • First, the Corporate Ethics Unit will present the results obtained and propose (i) to archive the report or (ii) to establish a resolution.
  • Following this presentation, the Corporate Ethics Unit will make the decision it deems appropriate. In the event that the reported facts are not sufficiently established, or if they do not constitute an infringement within the scope of the Whistleblowing Channel, the report and the actions taken will be archived.

If the Corporate Ethics Unit determines that the reported facts are sufficiently substantiated and constitute an infringement within the scope of the Whistleblowing Channel, it will issue a reasoned resolution, indicating the necessary legal measures to be adopted.

At any point in the procedure, the Corporate Ethics Unit may seek legal advice from an external expert engaged to provide guidance on the drafting of the facts, their classification, or the adoption of the most appropriate disciplinary measures in each case.

In the event of a conflict of interest, as described in the preceding section 5.3, the final decision will be adopted jointly by the chairman and secretary of the Board of Directors.

Enforcement of Sanctions

The application of corresponding sanctions or disciplinary measures will be the responsibility of the persons authorised to do so. In the employment sphere, the Human Resources Department will be responsible for sanctions. If these sanctions are of a commercial nature or require legal action, the Management will make the decision, and its enforcement will be carried out by persons with sufficient authority.

7. Protection of Personal Data

In designing this Channel, Sancal Diseño S.L complies with data protection regulations, in particular the Regulation (EU) 2016/679 (GDPR) and Organic Law (Spain) 3/2018 (LOPDGDD) and their complementary regulations.

Informative clause on the protection of personal data

The personal data collected within the framework of Sancal Diseño’s Whistleblowing Channel will be used exclusively to process the reports received and, where necessary, to investigate the reported facts, in compliance with the provisions of Spanish Organic Law 1/2015 of 30 March, and the current personal data protection regulations.

The data obtained that result in the opening of an investigation will be incorporated into the record of processing activities “Whistleblowing Channel”. Responsibility for said processing lies with Sancal Diseño, with CIF B30035968 and registered address at Pol. Ind. La Herrada C/ Príncipe de Asturias, parcel 6B, CP 30510, Yecla (Murcia), Spain.

Data contained in reports that are not admitted for processing will be deleted immediately. Data that is subject to processing will be retained in the information system only for the time strictly necessary to decide on the appropriateness of initiating an investigation; in any event, three months after the data is entered, it must be deleted from the system.

Both the whistleblower and the reported party will be duly informed, as appropriate, of the persons and entities to whom their data will be communicated, respecting the guidelines established in this policy, particularly with regard to the possible non-disclosure to the reported party of the whistleblower’s identity.

To exercise the rights of access, rectification, erasure, objection, restriction, and portability, a written request may be sent to the postal address SANCAL DISEÑO S.L Pol. Ind. La Herrada C/ Príncipe de Asturias, parcel 6B, CP 30510, Yecla (Murcia), Spain, or by email to [Insert Sancal email address here]. The request must include: the full name of the person concerned, a copy of their national ID, and the specification of their request.

Principle of Proportionality

Personal data collected in Sancal Diseño’s Whistleblowing Channel:

  • Will be strictly limited to what is necessary to process and, where applicable, verify the accuracy of the reported facts.
  • Will be processed in accordance with data protection regulations, for legitimate and specific purposes related to the investigation arising from the report.
  • Will not be used for incompatible purposes and will be adequate and proportionate.

Security and Confidentiality Measures

Sancal Diseño will implement the necessary technical and organisational measures to guarantee the security of the data collected, protecting them against unauthorised access or disclosure. It will ensure that the identity data of the whistleblower is not disclosed to the reported party during the investigation, always respecting fundamental rights, without prejudice to competent judicial proceedings.

APPENDIX I 

Reportable Conduct

Conduct reportable through Sancal’s Whistleblowing Channel includes any breach of the principles and standards of conduct established in the company’s Code of Ethics, available to all professionals on the Employee Portal.

Also reportable is conduct classified under the Criminal Code and other special laws that may give rise to criminal liability for Sancal Diseño S.L, such as:

Public Corruption Misleading Advertising Business Corruption
Money Laundering / Terrorism Financing Fraud Smuggling
Punishable Insolvency Crimes Involving Risks Caused by Explosives and Other Agents Obstruction of Enforcement
Securities Crimes Computer Damage Crimes Against the Rights of Foreign Nationals
Crimes Relating to Intellectual and Industrial Property Crimes Against Public Health Disclosure of Trade Secrets
Price Fixing Crimes Against Personal and Family Privacy Fraudulent Invoicing
Tax Fraud Counterfeiting of Currency and Stamped Documents Breach of Accounting Obligations
Bid and Auction Rigging Social Security Fraud Crimes Against Workers’ Rights
Grant Fraud / Fraud Against the EU General Budget Refusal to Cooperate with Inspections Crimes Against Natural Resources and the Environment

APPENDIX II

Report Submission Form

For reasons of security, encryption, and guarantee of anonymity, the report form is no longer managed on paper. To submit a report, please go to:

https://app.canaldedenunciassoftware.com/sancal-diseno-s-l/

Once there, the system will guide you step by step to complete the required fields.