WHISTLEBLOWING CHANNEL
Holcim EMEA Digital Center is firmly committed to ensuring that both its own conduct and that of its subsidiaries, employees, senior management and directors within the Holcim Group complies with and meets the terms of the laws in force and those of its corporate governance system, its principles and ethical values, as well as generally accepted social responsibility.
How does the Whistleblowing Channel work?
The Internal Reporting System (known as the Integrity Line at Holcim EMEA Digital Center) is a tool aimed at providing a safe, anonymous and confidential environment in which anyone with reasonable evidence may report the perpetration of serious or very serious administrative offenses, actions or omissions that could be classified as crimes or irregularities, or breaches of the Code of Business Conduct, the Supplier Code of Conduct or the internal guidelines that implement these codes, and any infringement of legislation in force.
Any third parties related to Holcim EMEA Digital Center that have reasonable evidence of any irregularities (“Whistleblowers”) may report this to Holcim EMEA Digital Center by means of this Channel. Employees of Holcim EMEA Digital Center shall always be required to report any reasonable evidence of any irregularities detected.
The Integrity Line protects and encourages employees and third parties with which Holcim has a commercial relationship (such as contractors, subcontractors and suppliers) to report the existence of behavior that could be deemed unethical, illegal or that contravenes our values and principles.
The Integrity Line allows users to raise these concerns without any fear of retaliation (and they may even do so anonymously). The information provided over this channel makes Holcim aware of reports of crimes or other suspicions of misconduct and helps ensure that appropriate and adequate measures are taken to address these situations.
When Holcim receives a report, confirmation of receipt will be sent within seven days. Based on the information furnished, the report will be investigated. Within three months (or six, in exceptional cases) after the confirmation of receipt is sent, an update on the report will be sent. We make every effort to protect whistleblowers’ identities and the confidentiality of reports sent, within the limits defined in applicable laws and regulations.
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Right to anonymity
It is possible to submit anonymous reports verbally or in writing over the Integrity Line. Whistleblowers can also choose whether to submit reports anonymously or not and, in the latter case, the informant’s identity is guaranteed to be kept confidential, thus never being revealed to third parties.
Guaranteed confidentiality
Anyone participating directly or indirectly in the processing of reports and in the corresponding investigations must keep the information received strictly confidential.
Confidentiality of the whistleblower’s identity
The confidentiality of the data related to the parties concerned, especially the whistleblower’s identity, if such party's identity is known, represents one of our guiding principles. Under no circumstances shall any details be revealed to anyone not involved in receiving and processing the report that enable such parties to be identified.
Prohibition of retaliation
Neither whistleblowers nor anyone else who collaborates in an investigation may be penalized or subjected to any negative consequences or retaliation. This safeguard also extends to any parties related to the whistleblower.
Rights of the reported person
The reported person is entitled to be informed of the actions or omissions ascribed to them and to be heard by the investigator. Such parties shall also have the right to be presumed innocent, the right of reputation and any other rights under applicable regulations.
Personal data protection
Personal data shall be processed in accordance with applicable data protection legislation and, in particular, pursuant to the provisions of Title VI (Whistleblower Protection) of Law 2/2023.
Preferred channel
Holcim has the Integrity Line, which offers whistleblowers the option of submitting reports on possible breaches or the potential perpetration of a crime or infringement of applicable regulations in various ways (by telephone, mail or an online form).
System manager
Holcim has a body in charge of managing the Internal Reporting System, which has delegated its management powers to the Compliance Officer, who can be contacted at integritylinemanager-esp@holcim.com
If you would like to file a report in person, please contact the Internal Reporting System Manager by email at:
