Internal Channel of ID Energy Group

Terms of Use

The internal information channel of the group of companies of which ID Energy Group, S.A. is the parent company (the “Internal Channel”) is a way to report regulatory infringements that take place within any of the companies that are part of said group (the “ID Energy Group”).

It is implemented in compliance with Law 2/2023, of February 20, regulating the protection of individuals who report regulatory infringements and fight against corruption. With the implementation of the Internal Channel, the ID Energy Group also aims to strengthen the culture of transparency and promote communication as a mechanism to prevent and detect infringements that may affect the companies within the ID Energy Group.

The Internal Channel is available to all individuals who, in the context of their labor, professional, or contractual relationship with any of the companies within the ID Energy Group (employees, interns, shareholders, contractors, subcontractors, among others), whether current or past, detect infringements and wish to report them to the ID Energy Group (the “Protected Persons”).

Through the Internal Channel, Protected Persons may submit, confidentially and, if applicable, anonymously, information regarding actions or omissions that occur within any of the companies of the ID Energy Group and that may constitute criminal or administrative offenses, whether serious or very serious.

The ID Energy Group, through its representative ID Energy Group, S.A., as the parent company, will acknowledge receipt of communications received from identified Protected Persons within the legally established period of seven days from receipt. Communications will be processed provided they are credible, substantiated, and fall within the objective scope of the Internal Channel. To do this, a maximum period of three months will apply, except in cases of particular complexity where the period may be extended for an additional maximum of three months, with prior approval from the governing body.

During the processing of communications, actions will be carried out diligently and promptly, respecting the rights of Protected Persons. When deemed necessary, the person responsible for handling the communication may contact the Protected Person to request additional information.

Reporting through the Internal Channel is not a prerequisite. Therefore, Protected Persons may, if they consider it necessary, submit complaints to the competent administrative or judicial authorities, as indicated in applicable regulations.

By using the Internal Channel, the Protected Person agrees to:

Privacy Policy

This privacy policy (the “Privacy Policy”) aims to inform you clearly and precisely about the processing of personal data collected through the “Internal Channel – ID Energy Group” web form.

Who is responsible for data processing?

The data controller will be the company within the group of companies of which ID Energy Group, S.A. is the parent company, to which the communication is linked. In any case, ID Energy Group, S.A., with NIF A-13.479.902, registered address at C/Malagón 10, CP 13005, Ciudad Real (Ciudad Real), as the managing parent company of the Internal Channel – ID Energy Group, is also responsible for the processing.

Where do your personal data come from?

We collect personal data directly from the data subject via the “Internal Channel – ID Energy Group” form. The data requested are strictly necessary for the purposes described below.

What is the purpose of processing your personal data?

The data controller will process your data for the purpose of managing, investigating, and responding to communications received through the Internal Channel in compliance with Law 2/2023, of February 20, regulating the protection of individuals who report regulatory infringements and the fight against corruption.

What is the legal basis for the processing?

The legal basis is compliance with a legal obligation.

Who will your personal data be shared with?

There is no intention to share the data with third parties unless necessary for the development and execution of the purposes of the processing, such as with the Public Prosecutor’s Office or the competent administrative authority as part of the investigation.

The data may be communicated to ID Energy Group, S.A. for centralized compliance management within the group companies, based on adequate coordination and better performance of the Internal Channel Manager’s functions.

How long will we keep your personal data?

We will keep your data for a period of three months, extendable by another three months if the complexity of the issue requires it. Once this legal period has elapsed, the data will be properly blocked until the limitation period for possible legal actions.

What are your rights?

Data subjects may exercise their rights of access, rectification, objection, erasure, portability, and restriction of processing at any time by sending a written communication to the address indicated in the first paragraph or by email to info@idenergy.group (Ref. Data Protection), indicating the right they wish to exercise. Finally, we inform you that you have the right to seek protection from the Spanish Data Protection Agency through its website www.agpd.es.

whistleblower channel