Ethical channel

 

MICRON WIND SOLUTIONS S.L. declares its zero tolerance for conduct constituting workplace harassment, sexual harassment, or harassment based on gender.

This channel is the way to report any situation constituting harassment, whether made by the person who has suffered the harassment or by any other person who has witnessed or is aware of the incident, whether their own staff or those from other companies.

MICRON WIND SOLUTIONS S.L. has a protocol for preventing and responding to workplace harassment, sexual harassment, or harassment based on gender, which is permanently available to all its employees.

Only situations of workplace harassment, sexual harassment, or harassment based on gender, and other conduct against sexual freedom that occur during, in connection with, or as a result of work, may be reported through this channel.

PRINCIPLES AND GUARANTEES ON WHICH MICRONIZACIONES’ CHANNEL FOR REPORTING WORKPLACE, SEXUAL, AND GENDER-BASED HARASSMENT IS BASED

In accordance with applicable legislation, this channel is based on the following principles:

  • General guarantee of confidentiality and anonymity, both of the information reported and of the identity of the complainant, as well as the details and progress of the complaint. Only the person designated as the investigator and the MICRON governing body will have access to the complaint, and only they will communicate with the complainant.
  • Hearing for the person reported.
  • Prohibition of retaliation for bona fide complainants.
  • Rights of the person under investigation
  • Personal data protection
  • Channel manager
  • Monitoring the processing of the complaint

FILING A COMPLAINT – PREVENTION OF HARASSMENT

  • Complaints may be filed anonymously by the person who feels harassed or by anyone who is aware of the situation.
  • Only the person designated by the MICRON Board of Directors as the person responsible for the Complaints Channel may access the channel’s emails.
  • Confidentiality is guaranteed regardless of how complaints are processed.
  • The complaint will be presumed to be true.
  • Once the complaint is received, the person in charge of processing it will assign a numerical code to each of the affected parties.
  • An acknowledgment of receipt will be sent within a maximum of three days along with the identification code.
  • Any evidence, images, videos, or documents that support or prove the reported facts may be attached, ensuring confidentiality and data protection.
  • In a first phase, called the preliminary or informal phase, an attempt will be made to resolve the harassment situation urgently and effectively to stop the harassment and reach a solution acceptable to both parties. This phase is discretionary for the parties and will depend on the victim’s expressed will, lasting a maximum of 7 business days.
  • If the preliminary phase is not activated or has been exhausted, the information file or formal procedure will be initiated, where the designated person will conduct the corresponding investigation. This procedure will last a maximum of 30 days, extendable in cases of particular complexity.
  • The resolution of the file is the final phase, in which MICRON’s administrative body, based on the report from the channel management manager, will make the appropriate decisions within 3 business days.
  • At all times during the investigation of the case, the MICRON administrative body will ensure that it adopts the precautionary measures it deems appropriate, leading to the immediate cessation of the harassment.
  • In addition to other precautionary measures, the MICRON administrative body will separate the alleged harasser from the victim.
  • If, even if harassment does not exist, inappropriate conduct or a situation of violence that is punishable by sanctions is found, the person designated as the investigator of the harassment case will also urge the MICRON administrative body to adopt the measures it deems appropriate.

This procedure does not impede the victim’s right to file a complaint at any time with the Labor and Social Security Inspectorate, as well as with civil, labor, or criminal courts.

This channel is not a service for consultations or for reporting emergency situations or imminent life-threatening situations. Complaints filed through this service will not receive an immediate response. If you need urgent assistance, please contact the public emergency services and state law enforcement agencies.

This channel is also not a service for filing customer complaints or for reporting any situation other than possible cases of workplace harassment, sexual harassment, or harassment based on gender within the company.

Any false or bad-faith complaints may be referred to the relevant judicial institutions.

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FORM FOR REPORTING HARASSMENT AT MICRON WIND SOLUTIONS

Email address where the confirmation of the report will be received
Please include as much detail as possible, including dates, locations, etc.
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    BASIC INFORMATION ON DATA PROTECTION

    Controller MICRON WIND SOLUTIONS, S.L.
    Tax ID: B-99417537
    Polígono Industrial El Portazgo, Units 4 and 5
    50011 Zaragoza (Spain)
    Purpose To process, investigate and/or resolve complaints related to workplace harassment, sexual harassment or harassment based on sex. The data will only be processed by the person designated to manage the whistleblowing channel, in accordance with the provisions of MICRON’s Harassment Prevention and Action Protocol. Absolute confidentiality and secure custody are guaranteed, applying appropriate security measures in accordance with the type of data processed and the associated information risk.
    Type of data Identification data and, depending on the information provided by the user in the complaint text or in the attached files, other types of personal data may also be included.
    Legal basis Compliance with a legal obligation.
    Recipients Your data may be disclosed exclusively in the event of external legal actions and to judicial bodies, State Security Forces and Corps or administrative authorities, where necessary.
    Retention period Your data will be retained for the minimum period necessary to determine whether an investigation should be initiated and, where applicable, for the duration of the investigation and resolution of the submitted complaints, and in any case for a maximum period of 3 months from the submission of the complaint.

    However, the data may be processed for a longer period outside the Whistleblowing Channel system if the outcome of the investigation process could give rise to legal action.
    Exercise of rights By writing to the controller’s physical address or by email at info@micronwind.com, enclosing a copy of your ID card or equivalent identification document and indicating “Ref. Personal Data – MICRON Whistleblowing Channel” for the processing of such rights by the data protection officer.

    If you believe that your rights have not been duly respected, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
    Further information Please consult our Privacy Policy.