Internal reporting system

INTERNAL REPORTING SYSTEM POLICIES.

The internal reporting system of THE ACADEMY COLEGIO BILINGÜE, S.L. constitutes the channel through which to report, confidentially and effectively, any information regarding any irregularities carried out by THE ACADEMY COLEGIO BILINGÜE, S.L. or its staff, that has been obtained within the framework of any employment or professional relationship with our organisation, in accordance with the provisions of Act 2/2023, of 20 February.

-The organisation has configured an internal reporting / whistleblowing system through the following channels:

·         In writing:

ü  Via email address: claims@theacademyschool.com

ü  Via postal mail, addressed to the Manager of the internal reporting system of the organisation THE ACADEMY COLEGIO BILINGÜE, S.L., via address: CAMÍ SON AMETLER VELL, 250, 07141, MARRATXI, BALEARIC ISLANDS, SPAIN.

·         Verbally:

ü At the request of the informant, the information may also be reported by way of a face-to-face meeting with the System Manager, within the maximum period of seven (7) days after the filing of the request.

-Apart from the foregoing channels, a complaint may also be filed with the external reporting channels of the competent authorities.

– After the complaint has been received, the Manager of the internal reporting system shall confirm receipt of the complaint to the complainant within the period of seven (7) days, in the event of nominal complaints. In any event, the complainant shall be informed of the rights and obligations established under personal data protection regulations.

– The Manager of the internal reporting system shall issue a reasoned report that shall uphold or dismiss the complaint filed, and shall justify, in any event, the adopted decision. The report shall be notified to the complainant and to the person concerned within the maximum period of three (3) months after the expiry of the period of seven (7) days subsequent to the reporting thereof, except in the event of situations of special complexity that may require said period to be extended, in which case, said period may be extended up to a maximum of another three (3) months.

– During the processing of the complaint, communication and contact may be maintained with the informant/complainant and, if considered necessary, the informant may be requested to provide additional information.

– It shall be ensured that the person concerned by the information or complaint is duly informed thereof, together with a brief summary of the facts thereof. Furthermore, the informant shall be informed of the right thereof to file pleadings, in writing, as well as the rights thereof regarding the processing of his or her personal data. Notwithstanding the foregoing, said information may be provided during the hearing stage if it considered that the prior provision thereof could facilitate the concealment, destruction or alteration of evidence.

– The Manager of the internal reporting system/whistleblowing channel shall guarantee the confidentiality of the personal data of all persons that make use of the internal reporting system/whistleblowing channel. Moreover, the Manager shall also guarantee said confidentiality even when the notification or report is carried out via other reporting channels that are not the established channels or directly to members of staff not responsible for said data processing.

– During the processing of the file, the persons concerned by the notification shall have the right to the presumption of innocence, the right to a legal defence and the right to access to the file, as well as to the same protection established for the informants in relation to personal data protection, thereby keeping confidential their identity and the particularities of the facts and information within the procedure.

.- The personal data processing as a result of the application of the foregoing procedure shall be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016, and the Personal Data Protection and Digital Rights Act 3/2018, of 5 December, and Parliamentary Act 7/2021, of 26 May, on the protection of personal data processed for the purposes of prevention, detection, investigation and prosecution of criminal offenses and the execution of criminal sanctions.

– The Manager of the internal reporting system/whistleblowing channel must immediately forward the information to the Public Prosecutor’s Office when the facts could indicatively constitute a crime or to the European Public Prosecutor’s Office, in the event that the facts affect the financial interests of the European Union.

– The organisation hereby guarantees that no reprisals shall be adopted against any person that reports any possible unlawful conduct or that reports any regulatory breach or that collaborates in the investigation or helps to resolve it.

– The persons that report or reveal any infringements set out in Section 2 of Act 2/2023, of 20 February, or any actions or omissions that may constitute a serious or very serious criminal offense or administrative infringement, shall have the right to the protection measures provided that the conditions established under Section 35 of said Act have been complied with. The protection measures are set out in Section 38 of Act 2/2023, of 20 February.

– The report or complaint shall be stored at the offices of the organisation, in accordance with its document archive and conservation policy.

– The organisation shall keep a register of all of the complaints received. The complaints shall be stored only during the period of time that is strictly necessary and proportionate for the purposes of the necessary compliance with the requirements established under Act 2/2023, of 20 February, on the protection of persons that report regulatory infringements and that governs the fight against corruption, as well as in accordance with the provisions of Section 24 and all other applicable sections of the Personal Data Protection and Digital Rights Act 3/2018, of 5 December.