Whistleblowing channel

Code of conduct and whistleblowing channel

Azkoyen, SA, as the parent company of the Azkoyen Group (hereinafter referred to as “Azkoyen” or the “Group”) and Coges S.p.A., declare that they absolutely reject any type of practice related to the commission of criminal acts, especially concerning corruption. For this reason, and in accordance with the principles established in its Code of Conduct and Compliance Model, the Group is committed to complying with all anti-corruption laws, strictly prohibiting any form of active or passive corruption at Azkoyen, without distinction of origin, destination, amount, etc., including where such illicit acts may benefit the Group.

As part of its Governance system, of which the Azkoyen Group is also an integral part, Coges S.p.A. has adopted the 231 Model for the prevention of the risk of crime.

With the adoption of the Organisational Model implemented, Coges aims primarily to establish a structured system to prevent the commission of crimes, within the scope of its business operations, considered “sensitive” and that are fully realised within the so-called risk areas, in such a way as to have a structured system of procedures and controls that reduce, ideally eliminating, the risk of committing prerequisite crimes.

You can find more information about our Organisational Model at this link: Corporate Compliance – Grupo Azkoyen

 

In compliance with legislative requirements, Coges also has a Whistleblowing Channel accessible here: WHISTLEBLOWING CHANNEL

The whistleblowing channel is intended for all professionals and stakeholders of the companies that make up the Azkoyen Group, who are or might be aware of a violation committed by any other worker, manager, or administrator, as well as customers, and suppliers.

Reports can be made by all employees, executives, members of the Board of Directors, or external collaborators of the Group subject to its authority, who have committed violations or behaviours among those provided for in the area below.

The purpose of the Reporting Channel is the reception, management, and processing of reports related to non-compliance or episodes of failure to comply with regulations, committed by employees or companies.
It is a confidential communication channel accessible to employees, customers, suppliers, shareholders, etc., linked to the Azkoyen Group, the Audit Committee, and the Management of the company.

For the management of the whistleblowing channel, in accordance with Italian Legislative Decree 24/2014, Coges S.p.A. and GRUPO AZKOYEN, SA, as joint data controllers, have mutually agreed upon their respective responsibilities for compliance with the obligations imposed by the GDPR, as follows:

• Both entities undertake to process the data in compliance with the provisions of the applicable data protection regulations.
• Both entities undertake to respond to requests made by data subjects exercising their ARCOPOL rights.
• If you wish to exercise your ARCOPOL rights with Coges, please send your request to responsabilesicurezza@coges.eu. If you wish to obtain information from Azkoyen, we provide a link to its privacy policy, where you can access more information.
• Both entities guarantee the implementation of appropriate technical and organizational measures pursuant to Art. 32 GDPR.
• Both entities undertake to notify data subjects of security incidents that pose a high risk to their rights and freedoms and that may affect their personal data.

For more information, consult the Whistleblowing Channel Policy and the Privacy Policy of the whistleblowing channel.