NEGOCIANTS´ ETHICAL CHANNEL
Welcome to the ethical channel that NEGOCIANTS S.L.U. (hereinafter, Vila Viniteca) has implemented so that its customers, employees, and suppliers can report violations of the law or our company's policies, in a secure and confidential manner.
Ethical channel managers
Vila Viniteca has designated a team in charge of the management and evaluation of the communications received through this channel, as well as for the investigation of the incidents and to resolve the procedure. Vila Viniteca seeks to guarantee the maximum independence, objectivity, and impartiality.
People responsible for the channel are qualified to carry out their functions entrusted to them.
This team is composed of the heads from different departments that are part of Vila Viniteca.
Behaviour, the object of communication
Based on the provisions of the current whistle-blower protection regulations, the following are some of the behaviors that may and/or should be reported through the channel, in case you become aware of them or become a victim of them:
- Workplace harassment
- Unethical actions
- Conflict of interest
- Fraud
- Corruption
- Criminal offenses (e.g. theft, robbery, sexual assault).
- Conduct contrary to business interests.
On the other hand, the channel must not be used /nor is it enabled to be used for the following purposes:
- The contracting of Vila Viniteca products or services
- Presentation of claims and complaints
- Sending job applications
- Exercising your data protection rights
- Requests related to HR
- Customer service
Maintaining a culture of integrity and business ethics is one of our objectives and this new channel is an important tool to ensure that the stakeholder can safely and confidentially report any concerns related to business conduct, compliance, or ethics.
How you can submit a communication
Communications may be submitted:
- Using the form linked at the bottom of this page
The communication shall include the identification data of the whistle-blower, basic contact data, the kind of infringement reported, and a description of the facts reported. Likewise, it shall be accompanied by the documents or other means admitted by law and lawfully obtained, which are to be used to prove those facts.
As well, Vila Viniteca is planning to create an external public channel under the Autoridad Independiente de Protección del Informante (A.A.I.) as an alternative to the private internal channels.
Anonymous communication
We understand that you may prefer to report without your identity being known; therefore, the channel form incorporates an option to submit the communication anonymously and confidentially, guaranteeing that your identity will not be recognized either by those responsible for the channel or members of the Ethics Committee or by third parties during the entire process of management, investigation, and resolution.
How to track the status of the procedure
The whistle-blower can contact the channel manager team by entering the code received after the submission of the communication in the review section below the web form. Open and transparent communication will be maintained with the whistle-blower throughout the management and investigation process. Updates will be provided on the status of the investigation and any action taken in response to the communication.
Communications will be handled confidentially and investigated in a fair and impartial manner.
Rights of the person who makes the communication
- Rights and guarantees for the whistle-blower:
- Guarantee of confidentiality, preserving their identity and any person in their environment. The identity of the whistle-blower may only be communicated to the persons authorized and designated for the management of the channel and investigation of the facts, to the competent judicial or administrative authorities, and to the Public Prosecutor's Office, within the framework of a criminal, disciplinary or sanctioning investigation.
- Respect for your privacy and the protection of your data.
- Guarantee of protection against possible reprisals (e.g. suspension of contract), when the whistle-blower makes the communication in good faith and informs of facts of which he/she has been a witness or has sufficient information and evidence to believe that they are true.
- Right to information.
- Independence, impartiality, and objectivity in the management of the communication and investigation of the facts.
Rights of the person affected by the facts
The person to whom the facts are attributed will also have rights and guarantees during the proceedings:
- Right to the presumption of innocence and honor.
- Guarantee of independence, impartiality, and objectivity in the management of the communication and investigation of the facts.
- Right to defense.
- Right to know the facts attributed to him/her and to have access to his/her file.
- Preservation of the identity.
- Guarantee of confidentiality.
False allegations
If, in bad faith, a communication containing false information is submitted, Vila Viniteca reserves the right to take whatever legal action may be necessary to demand liability and compensation for any damages that may be caused.
Personal data protection
In compliance with data protection regulations – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 Open in new window, on the protection of natural people with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulations) and the provisions of the Organic Law 3/2018, of 5 December, on Personal Data Protection and digital rights guarantee– it is reported that the processing of the information collected in the channel is handle by Vila Viniteca, as data controller, to investigate the facts.
Such processing is accomplished based on compliance with the legal obligations of the entity, as well as the exercise of a mission carried out in the public interest. The information will only be accessed by people designated and authorized. However, the data may be communicated to the public authorities within the framework of a procedure and, in the case of employees, to their legal representatives.
The data will be kept in the internal communications system as long as the beginning of the investigation –if Vila Viniteca decides to initiate the process– during the investigation and the resolution of the facts. Also, the communications received, and actions carried out will be kept in a record book for the minimum legal period established.
Interested individual parts may exercise their rights of access, rectification, deletion, opposition, limitation, and portability by submitting their request by email to [email protected] or by writing to C/ AGULLERS, 7, 08003, BARCELONA.
For more information, please see our privacy policy at: www.vilaviniteca.es.
We encourage all interested individual parts to use this channel. It is important for us to listen to your concerns and take appropriate action to resolve any issue. In addition, we remind you that Vila Viniteca prohibits any form of retaliation against whistle-blower who submit a communication in a good faith.
Access to the form
