Whistleblowing Channel

Terms of use

Mazars' Whistleblowing Channel is not an emergency service. In case of emergency, please contact the local authorities, or call 112.

This service shall only be used to send complaints to companies that have contracted the service with Mazars, guaranteeing the anonymity with regards to the whistlebower's name. In such case, you will have received training for such purpose.

Conditions for the user:

  • Please do not use this site to report events that represent an immediate threat to life or ownership.
  • It will not be possible to file information through the present channel that could be considered as strictly secret and confidential, or which should be safeguarded in interest of national security.
  • Take your time and provide as many details as possible. Take care not to supply details further than your name, which could reveal your identity (i.e. kinship, work post, etc.). Mazars guarantees the whistlebower's anonymity regarding his/her name, and not regarding information that, through the organization's analysis, could enable the whistlebower's identification.
  • If the organization verified that there has been bad faith in the whistlebower' complaint (i.e. using information known by the whistlebower as misleading or counterfeiting it), and Mazars was thus formally informed, Mazars will be forced to communicate the whistlebower's identity to the organization.
  • When you send the complaint, you will receive a key in your email account that will allow you to monitor your complaint, and to visualize messages to be conveyed by the Whistleblowing Channel until you are contacted by phone. We would appreciate it if you kept the key in a secure place.
  • The initial contact will be made by phone and data on your national identification number (DNI) will be requested.
  • The whistlebower is made liable for the truthfulness of all conveyed information, assuming consequences in case of acting in bad faith or contributing with false documentation.

Conditions for the contracting company:

  • Mazars will not be liable for the course of internal investigations.
  • Mazars shall only gather the whistleblower's documentation and document the information provided by him/her, so that measures are established as soon as possible to guarantee the security and validity of evidences, and the pertinent internal investigations are launched by the Organization's Audit Committee or by the body designated for such purpose.
  • If Mazars received a complaint in relation to a possible money laundering offence, it reserves the right to communicate the information to the Money Laundering Prevention Commission, without previously informing the contracting company.
  • If Mazars was compelled by law to collaborate with the authorities, it reserves the right to act on the basis of its obligations, without prior communication to the contracting company.
  • Clients that have contracted Mazars' Whistleblowing Channel service will have the freedom to determine how to act or not, based on the information conveyed by the whistlebower through Mazars' Channel.

Legal and Privacy Policy

Personal Data Protection

Identification of your personal Data Controller

The information and/or personal data provided by you will be processed by Mazars Auditores, S.L.P. as Data Controller, whose identifying details are the following:

  • NIF B-61622262.
  • Postal address: Alcalá, 63, 28014, Madrid.
  • Contact the of Data Protection Officer: compliants@mazars.es

Information processed by us

Mazars will process the information provided by you through this Website’s forms. Data that could be processed for the purpose/s on which you are being informed are the following:

  • Name

  • Surnames

  • Email

  • Telephone number

  • Company

  • Other data that could be identified in the description of the reported act.

Purposes for which your data are processed

Mazars shall process your data to carry out one or several of the following purposes, which are described below, as applicable and as previously informed on the first informative layer on data protection when collecting your data.

  • Process and manage consultations and requests performed through our contact form.

  • Manage and process your complaint.

Purposes of data processing performed by Mazars as Data Processor

If you provide us with personal data to present the complaint and, where applicable, for its subsequent monitoring, we inform you that your personal data will be processed by Mazars as Data Processor, of each one of the organizations contracting the whistleblowing channel service, and which may, where applicable, register the processing system on their corresponding processing activities registries.

Legitimation of the data processing

We inform you that the basis that legitimizes the processing of your data to manage and process consultations and requests performed by you is Mazars' legitimate interest to ensure the quality of our services.

When processing your data to manage and process your complaint, the basis that legitimates the processing of your data is the compliance with a mission in the public interest.

Retention of personal data

Personal data provided will be processed during the strictly necessary time to carry out the purposes on which you are being informed and, in any case:

  • When processing your data to manage and process your consultations and requests, your data will be preserved based on the following criteria: (i) management and processing of your consultation or request; (ii) existence of legal preservation obligations and statute-barred terms of eventual legal responsibilities; and (iii) suppression request sent by you.

  • When your data will be processed and the process will begin, the data will be selected during the time necessary to decide on the appropriateness to initiate an investigation on complained acts and, in any case, three months after receiving your data, we will eliminate from the complaint system, unless it was necessary to preserve them to evidence the functioning of our crime prevention model or their processing, or was required by the corresponding body in charge of investigating the complained acts, in which case they will be preserved as long as the corresponding legal obligations subsist.

Data recipients

We inform you that your data will not be assigned and will not be subject to international transfers, except in compliance with legal obligations or with your consent. However, we inform you that data processed to manage and process your complaint shall be communicated to the State Security Forces and Corps and, where applicable, to judicial authorities, as required.

Exercise of your rights

Under the terms and scope established by the regulations in force, you have right to:

  • Confirm whether Mazars is processing personal data concerning you or not, access such data as well as information related to their processing.

  • Request the rectification of inexact data.

  • Request the suppression of data when, among other reasons, they are no longer necessary for the purposes for which they were collected, in which case Mazars will cease processing data, except for the exercise or defence of possible claims.

  • Request the limitation of your data processing, in which case your data shall only be processed with your consent, except for their preservation and use for the exercise or defence of claims or with a view to protect another natural person or legal entity’s rights or for important public interest reasons in the European Union or a given member State.

  • Oppose to the processing of your data, in which case Mazars will cease processing the data, except for the defence of possible claims.

  • Receive in a structured format, of common use and machine readable, the personal data concerned, provided to Mazars, which will be directly transferred to another controller, as soon as it is technically possible.

You shall exercise these rights by sending your request to Calle Alcalá 63, 28014 in Madrid or sending an email to compliants@mazars.es, in both cases enclosing a copy of your ID card (DNI) or another equivalent document evidencing your identity.

We inform you that you could file a claim before the Spanish Data Protection Agency, if you consider that you have not obtained satisfaction from Mazars in the exercise of your rights, through the website: www.aepd.es

Modification of the present Policy

Mazars reserves the right to modify and/or update at any time the present Privacy Policy, as well as any information that may appear on the Website without the need of prior notice.

Create of a new complaint

Access your complaint

Usted ha entrado en el Canal de Denuncias ofrecido por Mazars Auditores, S.L.P. como servicio externo e independiente a HAYA REAL ESTATE.

Este canal asegura una comunicación anónima de las denuncias presentadas por el personal o terceros relacionados con la empresa que contrata los servicios, a la Comisión del Código Ético de ésta, u organismo designado a tal efecto.

Contratando este servicio las organizaciones estarán implantando un mecanismo de control efectivo, expresión de la debida diligencia ejercida por administradores y directivos para detectar, a través de un canal ágil e independiente, los hechos irregulares que puedan producirse en el seno de la organización, sin necesidad de conocer la identidad del denunciante.

Por su parte, los usuarios del canal, en el caso de que su compañía haya contratado este servicio, habrán recibido una formación o comunicación informándoles sobre la forma de proceder para comunicar conductas fraudulentas o que puedan atentar contra la normativa interna. Las conductas que no contravengan lo anterior no deben tramitarse a través del canal, sino a través de los cauces internos establecidos en su organización.

Todo particular que utilice el presente canal, se responsabiliza de la veracidad sobre su identidad y toda la información transmitida, y de actuar de buena fe. Mazars se reserva el derecho de desvelar la identidad del denunciante, si la compañía comunica formalmente a Mazars que el denunciante ha actuado de mala fe, así como en caso de requerimiento judicial.

Mazars no se responsabiliza de comprobar la veracidad de la información o documentación trasmitida, del uso que se pueda hacer del canal con fines distintos a los previstos, de las denuncias que vayan a empresas que no hayan contratado los servicios, ni de las acciones que tome la compañía que contrata los servicios a partir del Informe comunicado por Mazars a la Comisión del Código Ético de ésta.

 

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