Internal Whistleblowing Channel

Internal reporting channel

1. Purpose and scope

In compliance with Law 2/2023 of 20 February, on the protection of persons who report regulatory infringements and on the fight against corruption, Florentino Colección S.L. (hereinafter “Florentino” or the “Company”) makes available to its employees and other Whistleblowers an Internal Reporting Channel.

The purpose of the Internal Reporting Channel is to facilitate the reporting of:

Breaches of the Company’s Code of Conduct and other internal rules.
Conduct that may constitute infringements of European Union law (including, but not limited to, fraud, corruption, irregularities affecting the EU’s financial interests, or affecting the internal market).
Facts that may constitute a criminal or serious/very serious administrative offence.

2. Who may use the Internal Reporting Channel

The Internal Reporting Channel may be used by:

Employees and workers of Florentino.
Former employees.
Suppliers, collaborators, consultants and any third party with a contractual or professional relationship with Florentino.
Any person who has knowledge of facts that should be reported.

3. How to submit a report

Reports may be submitted by:

A) Online form
👉 Access the form

B) By postal mail
Florentino Colección S.L.
Internal Reporting Channel
Polígono Industrial Lalín 2000
Calle B 30-34
36500 Lalín (Pontevedra), Spain

Using the online form ensures registration, traceability, and confidentiality of the process.

4. Information that should be included in the report

To properly process the report, the Whistleblower is recommended to provide:

Identification of the fact or conduct.
Place, date and time (if known).
Persons involved.
Evidence or documentation (if available).
Any additional information that may help investigate the matter.

5. Confidentiality and protection of the Whistleblower

Florentino guarantees that:

The identity of the Whistleblower will remain confidential at all stages of the procedure.
Information will be treated with the utmost discretion.
Retaliation against the Whistleblower is strictly prohibited, including dismissal, sanction, intimidation or any action that may harm them.
The Company will adopt measures to protect the Whistleblower in the event of retaliation, in accordance with applicable law.

6. Management of the Internal Reporting Channel

The Board of Directors has appointed the Ethics Committee as responsible for the Internal Reporting System, which has delegated the management powers to one of its members, the Head of Internal Audit (hereinafter the “Delegate”).

The Delegate will be responsible for:

Receiving and recording reports.
Assessing their credibility and seriousness.
Initiating an internal investigation if appropriate.
Informing the Whistleblower of the status of the investigation.
Proposing corrective measures and monitoring.

7. Response deadlines

Florentino commits to:

Confirming receipt of the report within a maximum of 7 days.
Informing the Whistleblower of the status and outcome of the procedure within a maximum of 3 months, except in cases where a justified extension is required.

8. Investigation procedure

The internal procedure will be carried out guaranteeing:

Impartiality.
Presumption of innocence.
Confidentiality.
Right to be heard for the persons affected.

9. Data protection

Personal data provided through the Internal Reporting Channel will be processed in accordance with the Privacy Policy and applicable data protection regulations (GDPR and Organic Law 3/2018).

Data will be retained for as long as necessary to manage the report, and appropriate security measures will be applied.