Whistleblower channel - USA Group

Whistleblower channel

Regulation of the Whistleblowing Channel

  1. Objective: The whistleblowing channel aims to provide a secure and confidential means for employees, clients, and other stakeholders to report anonymously or identified any suspicious, illegal, fraudulent, or inappropriate activity in the company.
  2. Confidentiality: The confidentiality of the information provided will be guaranteed as far as possible and allowed by law. Only those who need to know the information to conduct an adequate investigation will have access to it.
  3. Accessibility: Access to the whistleblowing channel will be provided through different means, such as email, phone number, online form, or physical mailbox, so that reports can be made easily and accessible.
  4. Reporting process: Reports can be made anonymously or identified. Reports must be made clearly and in detail, indicating the place, date, and time the incident occurred, the individuals involved, and any other relevant information.
  5. Investigation: Reports will be investigated timely, fairly, and objectively. The investigation will be carried out by a designated team trained to conduct investigations effectively and professionally.
  6. Action: If the report is determined to be valid, and the illegal, fraudulent, or inappropriate activity is confirmed, appropriate measures will be taken to correct the situation, and the reporter will be informed of the actions taken. If any illegal action is identified, appropriate legal action will be taken.
  7. Protection of reporters: Reporters who make good faith reports will not be subject to retaliation or punishment in any way. The protection of reporters will be guaranteed, and measures will be taken to protect their confidentiality.
  8. Record-keeping: All reports, investigations, and actions taken will be properly documented, and accurate records will be maintained to meet any legal requirements and for follow-up purposes.
  9. Evaluation: The whistleblowing channel will be periodically evaluated to ensure its effectiveness, and measures will be taken to improve it if necessary.
  10. Disclosure: The existence and purpose of the whistleblowing channel will be communicated clearly and widely to all employees and stakeholders to ensure that the importance of making reports is understood when necessary.

Protocol for handling and processing reports from the whistleblowing channel:

  1. Receipt of reports: Reports can be received through different means, such as email (contact@usagroup.es), online form, or physical mailbox ( Polígono Industrial de Goitondo 48269 Mallabia). Upon receipt, the report will be logged and assigned a reference number for tracking purposes.
  2. Preliminary assessment: A preliminary assessment will be conducted to determine the seriousness and credibility of the report. This assessment will be carried out by a designated team to handle reports.
  3. Investigation: If the report is determined to be credible, a formal investigation will be initiated, and an investigation team will be appointed. The investigation will be conducted in a timely, fair, and objective manner.
  4. Notification of the reporter: The reporter will be informed that their report has been received and that an investigation is being conducted. The reporter will be informed of the expected timeframe for the investigation and any other relevant information.
  5. Confidentiality: The confidentiality of the reporter and the investigation will be maintained to the fullest extent possible, subject to legal requirements.
  6. Interviews: The investigation team will interview witnesses, gather evidence, and review relevant documents as part of the investigation.
  7. Analysis of evidence: The investigation team will analyze the evidence gathered and make a determination as to whether the report is substantiated.
  8. Reporting: A report will be prepared detailing the investigation and the findings. If wrongdoing is confirmed, the report will include recommendations for corrective action.
  9. Notification of action: The reporter will be informed of the results of the investigation and any corrective action taken.
  10. Follow-up: The investigation team will follow up on any corrective action taken to ensure that the problem has been resolved.
  11. Record-keeping: All reports, investigations, and actions taken will be documented and maintained for follow-up purposes.
  12. Evaluation: The effectiveness of the whistleblowing channel will be periodically evaluated to ensure that it is meeting its objectives.