Who should and can report incidents through the Whistleblower Channel?
All UNICORN employees, customers, suppliers and collaborators.
Who can be reported through the Whistleblower Channel?
All persons subject to UNICORN’s authority, regardless of their position, level of responsibility, contractual modality or geographical scope of work, provided that they act on behalf of and for the benefit of UNICORN.
What conduct can be reported?
The object of the complaint will be any fact that may contravene the provisions of the regulations in force (especially, but not exclusively, the Penal Code), as well as the rules of internal conduct (Code of Ethics), or the principles governing any of them, provided that the cause is an employee, manager, administrator or collaborator of UNICORN.
What are the requirements for the admission of the complaint?
Complaints must be based on evidence of wrongdoing. In no case should complaints be processed if they have no objective basis, are manifestly false, or are made with spurious motives such as intent to defame or retaliate.
If the information received lacks the essential data or the necessary clarity or completeness or if the facts reported do not have the appearance of an infringement, the opening of an investigation will not be warranted.
What are the rights of the participants and guiding principles of the channel?
The identity of the complainants shall not be disclosed to third parties.
All persons involved, in any capacity whatsoever, in the complaint and investigation procedure undertake to preserve the confidentiality of the communications received.
The confidentiality of the procedure will only cease in those cases in which there is a legal obligation of communication to third parties or there is a requirement of the competent authority.
Both the complainant and the accused shall be informed of the main milestones of the procedure in the terms set forth in the Policy for Use of the Complaints Channel, ensuring the greatest possible protection of the right of defense.
3.- PROHIBITION OF RETALIATION
A good faith whistleblower shall be protected against any form of retaliation, discrimination, disciplinary action or penalty on account of the report made; in particular, but not exclusively:
- suspension, dismissal, removal or equivalent measures;
- demotion or denial of promotion;
- change of position, change of work location, reduction of salary or change of working hours;
- denial of training;
- negative evaluation or references with respect to their work performance;
- imposition of any disciplinary measure, reprimand or other sanction, including monetary sanctions;
- coercion, intimidation, harassment or ostracism;
- discrimination, or unfavorable or unfair treatment;
- non-renewal or early termination of a temporary employment contract;
- damage, including damage to reputation, especially in social media, or economic loss, including loss of business and income;
- blacklisting on the basis of a sectorial agreement, informal or formal, which may imply that the person will not find future employment in that sector;
- early termination or cancellation of contracts for goods or services;
4.- PRINCIPLE OF GOOD FAITH
The complainant is responsible for the veracity of the data provided and of the facts narrated, undertaking to act in good faith.
5.- PROTECTION OF PERSONAL DATA
The treatment of personal data will be carried out in a way that guarantees their privacy and in any case in compliance with the current and applicable legislation.