Privacy Policy of the Internal Information System

The Internal Information System or Whistleblower Channel of BIOTECNOLOGIAS APLICADAS S.L. (hereinafter, “BTSA”) is the means through which employees, suppliers, customers and third parties with legitimate interest, can report irregular conduct, violations of the Code of Ethics or corrupt conduct in this company, which may constitute a crime in application of Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and fight against corruption.

BIOTECNOLOGIAS APLICADAS S.L. with CIF B80816531, and address at C/Arroba 4, 28805 Alcalá de Henares (Madrid) is responsible for the processing of the personal data provided through this means and it is expressly stated that they may be communicated to other third parties as processors, for the proper management of the complaint filed. All complaints submitted will be treated with the utmost confidentiality and for the purpose of investigating, processing and resolving the complaints submitted, anticipating and, where appropriate, correcting irregular behavior and / or contrary to the Code of Ethics. In no case may it be used as a mailbox for complaints or suggestions or as a customer service channel.

The personal data will be kept for the time necessary to decide on the appropriateness of initiating an investigation into the reported facts.

However, in the event that after the investigation process a judicial proceeding is initiated, the data may be kept for the additional time necessary until a final judicial resolution is obtained.

Complaints may be submitted anonymously or identified. In the case of an identified complaint, measures will be taken to protect against possible retaliation as provided for in the regulations in force. Complaints may preferably be submitted electronically, by clicking on the link provided at the end of this Policy, subject to acceptance of this Policy. The person responsible for the internal reporting system is the Secretary of the Compliance Body of BTSA, who will receive them and will transfer them, if appropriate, to the Investigation Body, which will follow the established internal investigation procedure.

Only the following may have access to the complaints:

1. El responsable del sistema y quien lo gestione directamente.
2. The person in charge of HR or the Investigating Body, only when disciplinary measures may be taken against a worker.
3. The Data Protection Delegate.
4. The data processors or sub-processors that may be appointed.

Any complaint or communication with criminal implications will necessarily involve the initiation of a file by the Investigating Body and the communication, where appropriate, to the State Security Forces and Corps, Administrations and Authorities and/or Courts and Tribunals.

For their admission and proper processing, the communications or complaints made must necessarily contain the following data:

• Identification of the complainant, except for anonymous complaints.
• Succinct statement of the facts or arguments supporting the communication/complaint and the provision of documents or testimonies considered appropriate.
• Person or department against whom the communication/complaint is directed.
• Place or address where the facts have occurred.

BTSA will adopt all security measures of technical and organizational measures necessary to prevent alteration, loss and unauthorized access or processing of such data and thus ensure the security of these.

The complainants may exercise their rights of access, rectification, opposition, deletion, limitation of processing and portability by email to the address: l.isla@btsa.com In case of anonymous reporting, the complainant may not exercise the rights indicated here.

I have read and I agree with the Privacy Policy of the Whistleblower Channel, I authorize the processing of the personal data provided and I want to file a complaint: click here