DATA PROTECTION AND VIDEO SURVEILLANCE PRIVACY POLICY
SDF is part of the COMAR Group of Companies (hereinafter also the “Group” or “COMAR”), whose parent company is the trading company “COMAR INVERSIONES Y DIRECCIÓN DE EMPRESAS, S.L.” whose identification data are as follows:
- Name of the company: COMAR INVERSIONES Y DIRECCIÓN DE EMPRESAS S.L.
- Address: Avenida Enrique Salgado Torres, 11, 15008 A Coruña (A Coruña)
- CIF: B15581168 – CNAE: 6420 (activities of holding companies)
- E-MAIL of the Data Protection Officer: [email protected]
Registered in the mercantile registry of A Coruña, volume 1.858, General section, folio 89, page nº C-17.142, 1st inscription.
In line with the provisions of the Code of Ethics and the applicable internal regulations, Grupo COMAR pursues the development of its professional activity with integrity, promoting ethical behavior, respect for human dignity and compliance with current regulations.
To these ends, COMAR has designed an Internal Whistleblower Information and Protection System (hereinafter, also the “System” or “Internal Information System”) consisting of the Whistleblower Channel (hereinafter, also the “Channel”) that the Group has had since 2017, and which is implemented as a formal mechanism for consulting or reporting irregularities through a technological platform.
The Policy is also applicable to all persons who provide professional services to the Group, who must act with integrity and always in compliance with the law and applicable internal regulations, and must cooperate to prevent irregular actions. In this regard, it is the duty of directors, managers, employees, interns or any other person who maintains a relationship of hierarchical dependence with COMAR, regardless of their functional, hierarchical position, employment status or territory in which they operate (hereinafter, also the “Personnel”), to report any internal irregularity or act contrary to the law, past, present or future, through the Channel.
Additionally, it is promoted that any person (natural or legal) who has had, has or may have a professional relationship (for example, suppliers, collaborators, contractors, agents, etc.) with COMAR (hereinafter, also the “Third Parties”) also use the Channel in the cases regulated in this Policy and in the Development Procedure, as a formal mechanism for communicating irregularities and regardless of other ordinary communication channels made available to Third Parties.
Therefore, the Personnel must and the Third Parties may communicate the knowledge or motivated suspicion of irregular conduct or that may imply a breach of current legislation, as well as the Code of Ethics and the rest of COMAR’s internal regulations, especially any behaviors that could constitute a serious or very serious administrative or criminal offense, including those related to the Public Treasury and Social Security, as well as in the labor field infractions related to safety and health at work, all without prejudice to the protection established in the specific regulations that may be applicable.
The Internal Information System is the preferred channel to report these behaviors through the address https://grupocomar.integrityline.com
