Internal Information System

Structure of the System

The AZTI Internal Information System includes:

1. Internal Information System Policy: establishes the principles and guidelines ensuring integrity, transparency, and compliance.
2. Person Responsible for the System: Cristina Elorriaga, formally appointed as the Person Responsible for the Internal Information System, overseeing its correct operation and compliance with all legal guarantees.
3. Internal Reporting Channel: a confidential, independent, and secure mechanism that allows communication of potential breaches of the law or of the Code of Conduct, in accordance with Article 9 of Law 2/2023.
4. Management Procedure: regulates the reception, processing, investigation, and resolution of communications in an objective, impartial, and secure manner.

Purpose of the Channel

The Internal Information System is intended to receive communications regarding possible criminal offences, serious or very serious administrative infringements, as well as breaches of AZTI’s Code of Conduct or internal policies committed in the course of professional activities.

This channel must not be used for general inquiries, HR issues, or personal complaints, which should be submitted through ordinary internal procedures.

Principles of Operation

The handling of reports is governed by the following principles:

1. Anonymity and Confidentiality: The informant may choose to report anonymously or with identification. In all cases, the confidentiality of the informant’s identity and of any third parties mentioned is guaranteed, as provided in Articles 31 and 32 of Law 2/2023.
2. Prohibition of Retaliation: AZTI guarantees full protection of informants acting in good faith against any form of retaliation, threat, or attempt thereof.
3. Protection of Personal Data: Processing of personal data is carried out in accordance with the EU General Data Protection Regulation (GDPR) and the Spanish Organic Law 3/2018 (LOPDGDD). Data will be stored only as long as necessary to decide on the initiation of an investigation and, if applicable, while it remains open, never exceeding the legal limit of three months.
4. Rights of Affected Persons: AZTI guarantees the rights of persons affected by a report, including their rights to defence, presumption of innocence, and data protection.
5. Good Faith and Responsible Use: The reporting channel must be used in good faith. False or abusive communications may result in disciplinary or legal liability, in accordance with Article 9.3 of Law 2/2023.

Communication Channels

Reports may be submitted safely, confidentially, and, if desired, anonymously through:

1. Dedicated email: canal@azti.es
2. Telephone contact: requesting to speak with the Person Responsible for the Internal Information System, Cristina Elorriaga
3. Secure online form
4. In-person or video meeting, upon request
   
   

Informants may also report directly to the Independent Authority for the Protection of Whistleblowers (A.A.I.), to regional authorities, or to any other competent body, in accordance with Articles 16 and 17 of Law 2/2023.

Ethical Commitment

AZTI reaffirms its commitment to integrity, transparency, and ethical conduct, ensuring that its Internal Information System serves as an effective tool for preventing, detecting, and addressing irregularities, thereby strengthening its compliance culture and corporate responsibility.