APOLO ABOGADOS
Whistleblowing Channel
The whistleblowing channel used by APOLO ABOGADOS ensures the confidentiality of the reporting party. Our whistleblowing channel offers the following options:
- Confidential Report: The reporting party may submit a report by providing their contact and identification details in order to facilitate communication and the submission of additional information and supporting details (not recommended).
- Secure Confidential Report: The reporting party may submit a report by providing their contact and identification details in order to facilitate communication and the submission of additional information and supporting details. However, the whistleblowing channel software encrypts such information and acts as a communication gateway with the reporting party, ensuring that no one can identify them and providing the highest level of confidentiality and protection.
- Anonymous Report: The reporting party may submit a report without providing contact or identification details due to concerns about suffering any form of retaliation.
- **Without prejudice to cases in which a report is submitted anonymously, the information provided by the Reporting Party who initiates the procedure, as well as the information collected throughout the investigation, shall be processed by APOLO ABOGADOS exclusively for the purpose of preventing the commission of any act or conduct that may be contrary to the law, including violations of APOLO’s corporate and good governance framework, in accordance with APOLO’s Code of Ethics. The legal basis for the processing of personal data is the existence of a public interest, in accordance with the Organic Law on the Protection of Personal Data, published in Official Gazette Supplement No. 459 of May 26, 2021.
If the information provided allows for your identification, please be advised that your personal data will not be disclosed to third parties except where legally required or where necessary to protect APOLO’s or third parties’ legal interests. Notwithstanding the foregoing, your personal data may be accessed by: (1) individuals responsible for internal control and compliance functions; (2) APOLO personnel responsible for the management and oversight of human resources where disciplinary measures against an employee may be warranted; and (3) third parties acting on behalf of APOLO, where such access is essential for the provision of a specific service related to this whistleblowing channel.
Your personal data, as well as the data of employees and third parties provided through the whistleblowing channel system, shall be retained for the period necessary to determine whether an investigation into the reported facts should be initiated. In all cases, six months after the data is entered, it shall be deleted from the Whistleblowing Channel, unless the purpose of retaining such data is to provide evidence of the operation of the crime prevention model. After this period, the data may continue to be processed by the body responsible for investigating the facts during the investigation of the Report and the processing of the corresponding proceedings. Thereafter, the data shall be duly blocked for the periods arising from the applicable statute of limitations for legal actions.