Whistleblower Channel Privacy Policy
The Whistleblower Channel of NUCHAR, a brand of FONCASAL TRADING S.L.U. (hereinafter, "FONCASAL"), is the means through which employees, suppliers, customers and third parties can report irregular conduct, violations of the Code of Ethics and corrupt conduct in FONCASAL and/or investee companies, which may constitute a crime.
FONCASAL is responsible for the treatment of the personal data provided. 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. Under no circumstances may it be used as a mailbox for complaints or suggestions or as a customer service channel.
Personal data will be kept for as long as it is necessary to decide whether to initiate an investigation into the reported facts.
However, in the event that a judicial proceeding is initiated after the investigation process, the data may be retained for the additional time necessary until a final judicial decision is obtained.
Complaints may be submitted anonymously or identified. In case of identification, measures will be taken to protect against possible retaliation. Complaints may be submitted by clicking on the link provided at the end of this Policy, subject to acceptance of this Policy. FONCASAL's Compliance Officer will receive them and will transfer them, if appropriate, to the Investigation Body, which will follow the established investigation procedure.
They will only be able to access complaints:
- The person responsible for the system and whoever manages it directly.
- The HR manager or the Investigating Body, only when disciplinary measures may be taken against an employee.
- The Data Protection Officer.
- The persons in charge of the treatment that eventually may be designated.
Any complaint or communication with criminal implications will necessarily imply 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.
In order to be admitted and properly processed, the complaints must necessarily contain the following data:
- Complete identification of the complainant (except for anonymous complaints)
- Brief statement of the facts or arguments supporting the communication/complaint.
- The person or department against whom the communication/complaint is directed (the respondent).
- Place or address where the events occurred.
FONCASAL will adopt all the necessary technical and organizational security measures to prevent the alteration, loss and unauthorized processing or access to such data and thus ensure the security of these.
Complainants may exercise their rights of access, rectification, opposition, suppression, limitation of processing and portability by sending an e-mail to the following e-mail address protecciondatos@vigent.pt In the case of an anonymous complaint, the complainant may not exercise the rights set forth herein.
I have read and agree with the Privacy Policy of the Complaints Channel, I authorize the processing of the personal data provided and I want to file a complaint: click here here.
