Ethical Channel – Micron Spain

MICRONIZACIONES DE PRODUCTOS QUÍMICOS, SL declares its zero tolerance for the occurrence of conduct that constitutes workplace harassment, sexual harassment or harassment based on sex.

This channel is the way to report any situation that constitutes harassment, whether carried out by the person who has suffered harassment or by any other person who has witnessed or is aware of the fact, whether it is its own staff or from other companies.

MICRONIZACIONES DE PRODUCTOS QUÍMICOS, SL has a prevention and action protocol against workplace harassment, sexual harassment or harassment based on sex that is permanently available to all its staff.

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

PRINCIPLES AND GUARANTEES ON WHICH THE MICRONIZACIONES CHANNEL FOR COMPLAINTS FOR WORKPLACE, SEXUAL AND SEX-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 communicated and of the identity of the whistleblower and data and progress of the complaint. Only the person designated as the instructor and the MICRONIZACIONES management body will have access to the complaint and only they will communicate with the whistleblower.
Hearing of the person accused.
Prohibition of retaliation for whistleblowers in good faith.
Rights of the person investigated
Protection of personal data
Channel manager
Monitoring of the processing of the complaint

COMPLAINT PREVENTION – HARASSMENT PREVENTION

Complaints may be anonymous and may be submitted by the person who feels harassed or by anyone who is aware of the situation.
Only the person designated by the MICRONIZACIONES Administration body as the Person Responsible for the Complaints Channel may access the channel’s emails.
Confidentiality is guaranteed regardless of the way in which complaints are processed.
The complaint will be presumed to be true.
Once the complaint has been received, the person in charge of processing it will assign a numerical code to each of the affected parties.
Within a maximum period of three days, an acknowledgement of receipt will be sent along with the identification code.
All evidence, images, videos or documents that support or prove the reported facts may be attached, guaranteeing confidentiality and data protection. In the first phase, called the preliminary or informal phase, an attempt will be made to resolve the harassment situation urgently and effectively in order to stop the harassment situations and reach a solution accepted by the parties. This phase is discretionary for the parties and will depend on the will expressed by the victim in this regard, with a maximum duration of 7 working 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 carry out the corresponding investigation, with a maximum duration of 30 days, extendable in cases of special complexity.
The resolution of the file is the last phase, in which the MICRONIZACIONES administration body, based on the report of the Channel Management Manager, will adopt the appropriate decisions in this regard, within 3 working days.
At all times, during the instruction of the file, the MICRONIZACIONES administration body will ensure that the precautionary measures it considers appropriate are adopted, leading to the immediate cessation of the harassment situation.
Apart from other precautionary measures, the MICRONIZACIONES administrative body will separate the alleged harasser from the victim.
If, even if there is no harassment, any inappropriate behavior or situation of violence is found that may be punishable, the person designated as the instructor of the harassment file will also urge the
MICRONIZACIONES administrative body to adopt measures that are considered pertinent in this regard.

This procedure does not prevent the victim’s right to file a complaint at any time before the Labor and Social Security Inspection, as well as before the civil, labor or criminal jurisdiction.

This channel is not a consultation service, nor for reporting emergency situations or imminent risk to life. Complaints filed through this service will not receive an immediate response. If you need urgent help, please contact the public emergency services and state security forces.

This channel is not a service for filing customer complaints, nor for reporting any other situation other than possible cases of workplace harassment, sexual harassment or harassment based on sex within the company.

Any false complaint or one made in bad faith may be forwarded to the relevant judicial institutions.

BASIC DATA PROTECTION INFORMATION
Controller:	MICRONIZACIONES DE PRODUCTOS QUÍMICOS SL CIF B-99417537, Calle Panama, 12. Polígono Centrovía. 50196, La Muela, Zaragoza, Spain
Purpose:	To process, investigate and/or resolve complaints of workplace, sexual or gender-based harassment. They will only be processed by the person in charge designated for the management of the complaints channel in accordance with the provisions of the MICRONIZACIONES Protocol for the prevention and action against harassment. The most absolute confidentiality and custody are guaranteed under security measures appropriate to the type of data and the risk of the information processed.
Type of data:	Identifiers and, depending on what the user indicates in the text of the complaint or attached files, other types of data may be contained.
Legitimation:	Compliance with a legal obligation.
Recipients:	Your data may be transferred exclusively in the case of external legal advisors and to judicial bodies and to the State Security Forces and Corps or administrative authority, when necessary.
Retention period:	Your data will be kept for the time necessary to decide on the appropriateness of initiating an investigation and, where appropriate, while the investigation and resolution of complaints filed is carried out, and always for a maximum period of 3 months from the filing of the complaint. However, the data may be processed for a longer period outside the Complaints Channel system, in the event that the result of the investigation process may result in the need to exercise the appropriate legal actions and/or that may give rise to legal proceedings.
Exercise of rights:	To the physical address of the person responsible or by email com-pras@micronspain.com attaching a photocopy of your ID or substitute identification document and indicating “Ref. Personal Data Complaints Channel MICRONIZATIONS” for the processing of said rights by the Privacy Officer). If the exercise of your rights is not attended to, you can file a complaint with the Spanish Data Protection Agency (www.agpd.es)
More information	Legal notice and Privacy Policy

FORM FOR REPORTING HARASSMENT SITUATIONS IN MICRON SPAIN