Cyberclick has set up an Internal Reporting System, called the Ethics Channel. Ethics Channel is the preferred channel for reporting actions or omissions that may constitute breaches of European Union law or that may constitute a serious or very serious criminal or administrative offence, provided that the offence can be dealt with effectively and if the whistleblower considers that there is no risk of retaliation.
Cyberclick's Ethics Channel was created within the framework of Law 2/2023 of 20 February on the protection of persons who report regulatory infringements and the fight against corruption. The text below serves the following specific objectives:
The Ethics Channel is available to the Cyberclick team and its external audiences, such as suppliers, customers, partners or any person who maintains any kind of relationship with us, through the following email: email@example.com
The operation and management of Cyberclick's Ethics Channel is governed by the following general principles:
Anonymous communication of information through the Ethics Channel is permitted. In addition, it is essential to guarantee the confidentiality of the informant with regard to his or her identity and the content of the communications he or she makes.
It is not compulsory for the management of the Ethics Channel for communications to be anonymous, however, the rule allows for anonymity, as this is the best guarantee for the defense and protection of the informant. Therefore, if the informant chooses anonymity, his or her identity can never be revealed.
The informant's identity will never be the object of the right of access to personal data and the possibility of communicating this identity is limited only to the judicial authority, the Public Prosecutor's Office or the competent administrative authority, requiring that in any case access to it by third parties be prevented.
Even if the informant freely chooses not to conceal his or her identity, the report on the resolution of the investigation carried out on the occasion of a disclosure of information shall never refer to the identity of the informant or of the parties involved, in order to ensure due confidentiality.
Communications through the Ethics Channel shall be made on the basis of respect and good faith.
A reporting person making a disclosure shall make such a disclosure whenever he has a genuine suspicion that the information provided is true, complete and accurate, irrespective of whether, after the process of investigation, it is verified that the information provided does not constitute an infringement.
Good faith is the expression that the whistleblower's behaviour is civic and therefore does not communicate false or unlawfully misrepresented information.
The Ethics Channel must be easily accessible to Cyberclick employees and to third parties who maintain or have maintained some kind of relationship with Cyberclick, and the informant must receive clear information about its access and operation.
Cyberclick's Ethics Channel will be publicly known and accessible through the website www.cyberclick.net, specifically, through a specific email address for this purpose: firstname.lastname@example.org
All communications of information received through Cyberclick's Ethics Channel will be treated and managed according to the same criteria, in accordance with that established in the Procedure for the management of information received through the Ethics Channel.
The management rules of the Ethics Channel have been regulated in a procedure, which means that all communications are treated equally and managed according to the same criteria, regardless of who communicates, who is affected and the possible implications of the communication, so that no communication of information will have a certain privilege over the others.
In application of the principle of fairness, when it is revealed that the reporting person is a specific employee, the People Operations team will be informed to ensure that the person has not been affected by any negative consequences. In the event that action is taken against the reporting employee, it may involve the commission of employment offences.