We, at Ravetllat Aromatics S.L., Tax Identification Number B60917580 (the “Company“), are committed to the highest standards of transparency, honesty, and accountability. To enable our employees and relevant third parties associated with the Company to express any concerns regarding specific aspects of the Company’s activities, this whistleblowing policy outlines how we support you in reporting irregularities, allowing you to raise concerns safely, know who to contact, and how to make a whistleblowing report (“whistleblowing report“).
Additionally, this policy describes how we ensure that the support provided to you is responsible and compliant with the law, as outlined in Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law (the “Whistleblowing Directive”). Lastly, the policy also explains your rights and how you can exercise them.
If you have any questions about this whistleblowing policy and/or how to make a report, please contact us using the details provided below.
1. Who can be a whistleblower?
1.1 You, as a whistleblower, may be an employee of ours or a self-employed individual, shareholder, or a member of the administrative, management, or supervisory body. You may also be a volunteer or an intern, whether paid or unpaid. As a whistleblower, you may also be someone working under the supervision and direction of our contractors, subcontractors, and suppliers.
1.2 Note that you can also be a whistleblower even if your employment relationship has ended or has not yet begun.
2. Who is responsible for whistleblowing reports?
2.1 The Company is responsible if you make a report under this policy. As such, we are obligated to protect you, including ensuring that your identity is not disclosed to anyone beyond the authorized individuals who receive the information in your report (unless you give explicit consent or disclosure is required by law). We also ensure that you are not subjected to retaliation.
2.2 However, you also bear some responsibility under this whistleblowing policy. We expect you to provide only information and personal data relevant to the handling of a whistleblowing report. We also request that you do not use this policy to report personal grievances related to work, such as interpersonal conflicts between yourself and other employees. Personal work-related complaints should be raised with your supervisor, manager, or the relevant responsible person.
3. What can be reported under a whistleblowing report?
3.1 If, during your relationship with us, you acquire information and have reasonable grounds to believe there is misconduct or breaches of applicable rules or regulations concerning us, you can file a whistleblowing report regarding the matter.
3.2 The Whistleblowing Directive specifically emphasizes the importance of reporting irregularities in the following areas:
(i) Public procurement;
(ii) Financial services, products, and markets, and the prevention of money laundering and terrorist financing;
(iii) Product safety and compliance;
(iv) Transport safety;
(v) Environmental protection;
(vi) Radiation protection and nuclear safety;
(vii) Food and animal safety, health, and welfare;
(viii) Public health;
(ix) Consumer protection;
(x) Privacy and personal data protection.
We strongly encourage you to report any concerns in these areas.
3.3 Note that “reasonable grounds” means that, given the circumstances and the information available to you at the time of making a report, you believe the matter reported to be true.
4. Where can you file a whistleblowing report?
4.1 We encourage you to submit a whistleblowing report in writing, orally, or both. Oral reports can be made via telephone and, upon request, through a physical meeting with the designated impartial person or department, as specified in the contact details below.
4.2 Written reports can be filed using our external whistleblowing system, Whistlelink. The platform is managed by a third party, specifically Whistleblowing Solutions AB, and is available 24/7. File a report through Whistlelink here: https://ravetllat.whistlelink.com/
4.3 We will acknowledge receipt of your whistleblowing report within seven days of receiving it. For your information, we have also appointed an impartial person (see contact details below) to follow up on the report, maintain communication with you, request further information if necessary, and provide feedback within three months of receiving your report.
4.4 You may choose to file your whistleblowing report anonymously. This does not affect your rights and protections under the EU Whistleblowing Directive. However, complete anonymity may limit our ability to investigate the situation or take the actions we would like to pursue.
4.5 Finally, if you encounter difficulties or if internal reporting is not suitable, you may report externally to the competent authorities or, where applicable, to the institutions, bodies, offices, or agencies of the European Union. The national authority in Spain is the Independent Informant Protection Authority (A.A.I.), under the Ministry of Justice.
5. Personal Data
5.1 We aim to always protect the personal data we process to the best of our ability. This means we are committed to safeguarding your privacy and complying with applicable personal data legislation, including but not limited to the General Data Protection Regulation (GDPR).
5.2 When you submit a whistleblowing report, we will process the personal data contained in it to fulfill our legal obligations under, among others, the Whistleblowing Directive. More information about how we process personal data in whistleblowing reports can be found in our privacy policy.
6. What are your rights?
6.1 We are committed to implementing and maintaining necessary and appropriate measures to prohibit any form of retaliation against you for submitting a whistleblowing report, including threats of retaliation or attempts thereof.
6.2 Retaliation prohibition includes actions such as:
(a) Suspension, dismissal, or equivalent measures;
(b) Demotion or withholding promotions;
(c) Job reassignments, changes to workplace, salary reduction, or work schedule changes;
(d) Suspension of training;
(e) Negative performance evaluation or employment reference;
(f) Disciplinary measures, reprimands, or other sanctions;
(g) Coercion, intimidation, harassment, or ostracism;
(h) Discrimination or unfair treatment;
(i) Failure to renew or early termination of a temporary employment contract;
(j) Damage to reputation, particularly on social media, or financial loss;
(k) Blacklisting in a sector or industry, preventing future employment;
(l) Early termination or cancellation of goods or services contracts;
(m) Cancellation of a license or permit.
6.3 Additionally, the competent authority in Spain provides complete, independent, easily accessible, and free information and advice on available procedures, resources, protection against retaliation, and your rights. The national authority is the Independent Informant Protection Authority (A.A.I.), under the Ministry of Justice.
7. How to contact us?
If you have questions about this whistleblowing policy and/or how to file a report, please contact us using the following details:
7.1 Company Contact Information:
7.1.1 Marta Sol Rico
Email: [email protected]
Phone: +34 933450158
7.1.2 Andrea Cornudella Ravetllat
Email: [email protected]
Phone: +34 607326653
7.2 Información de contacto de Whistleblowing Solution AB
7.2.1 Maria Boboc
Email: [email protected]
Phone: +34 683530248
The entire content of this page has been provided in both Spanish and English. While both versions are considered authentic, the Spanish text shall take precedence and govern interpretation for legal purposes.