Girbau is committed to conducting business with integrity, transparency and accountability. We encourage employees and others connected with our business to raise concerns where they believe that wrongdoing, misconduct or a breach of legal or ethical standards may have occurred.

Girbau provides a confidential reporting channel through which concerns can be raised and appropriately investigated.

Reports may relate to matters including suspected fraud, corruption, breaches of law or regulation, health and safety concerns, unethical conduct or other serious wrongdoing.

Concerns can be reported confidentially through Girbau’s established reporting channels.

By email:
compliance@girbau.com

In writing:
For the attention of the Compliance Officer
Girbau, S.A.
Carretera de Manlleu, km 1
08500 Vic, Barcelona
Spain

Where appropriate, you may also request a confidential meeting with the Compliance Officer to discuss your concern.

Anonymous reports may also be submitted through Girbau’s reporting arrangements where this option is available.

Reports will be handled appropriately and, where possible, confidentially.

Girbau will take reasonable steps to protect the identity of individuals who raise concerns and of other individuals identified in a report, subject to applicable legal requirements and the need to investigate the matter appropriately.

Reports will be reviewed and, where appropriate, investigated by authorised individuals.

Where further information is required and contact details have been provided, Girbau may contact the person who raised the concern.

Individuals who are the subject of a report will be treated fairly and with appropriate regard for their rights, including the presumption of innocence.

This replaces a huge amount of the Spanish section referring to Article 5.2, seven-calendar-day acknowledgements, three-month investigations, Spanish prosecutors etc.

Those deadlines might be mandatory for Girbau S.A. under Spanish law, but we shouldn’t present them as UK statutory requirements.

Girbau is committed to providing an environment in which genuine concerns can be raised without fear of retaliation.

Individuals who raise concerns in good faith will not be subjected to retaliation as a result of making a report.

Girbau will take appropriate steps to protect confidentiality and prevent victimisation or other detrimental treatment, in accordance with applicable law and company policies.

Personal data provided in connection with a report may be processed for the purposes of assessing, managing and investigating the concern and taking appropriate action where necessary.

Access to personal data relating to a report will be restricted to authorised individuals and service providers where access is necessary for the management or investigation of the matter.

Personal data will be retained only for as long as necessary for the purposes for which it was collected and to meet applicable legal, regulatory or record-keeping requirements.

Where personal data is transferred internationally, appropriate safeguards will be applied in accordance with applicable data protection law.

For further information about how Girbau processes personal data and your data protection rights, please see our Privacy Policy.

Depending on the circumstances and applicable law, individuals may also have the right to report certain concerns to an appropriate external authority or prescribed body.

Using Girbau’s internal reporting channel does not prevent an individual from making a protected disclosure to an appropriate external body where permitted by law.