Ethics Channel


In accordance with the provisions of the Code of Ethics approved by the Ethics Committee of the TITÁN Group (hereinafter, “TITÁN”) on 20 September 2018 and updated on 16 September 2019, an Ethics Channel is made available to TITÁN staff, as well as to third parties outside of TITAN, to report to the Ethics Committee any inappropriate or irregular conduct, or a conduct that is likely to infringe the legislation in force, the Code of Ethics, or the internal policies, protocols and processes of TITÁN.

The communications made to the Ethics Committee may be sent via the e-mail address canaletico@fabfolch.com. These will include, by way of example, the following information:

1. Details of the informant (name and surname, telephone number, e-mail address and relationship with TITÁN)

2. Details of the person or persons against which the communication is directed (name and surname, and relationship with TITÁN)

3. Date on which the reported facts occurred

4. Description of the facts reported

5. Documents that prove the existence of the reported facts

Equally, the communications made to the Ethics Committee may be sent via the following form:

Details of the informant

Details of the person or persons against which the communication is addressed

Documents that prove the existence of the reported facts



Having completed the report to the Ethics Committee, the latter will initiate the pertinent process of analysis, investigation and resolution, in accordance with the provisions of the approved Protocol for management, investigation and response to communications received at the TITÁN Ethics Channel.

The persons carrying out a communication via the reporting channels state and guarantee that the personal data provided are true, accurate, complete and up-to-date and hold TITÁN harmless for any liability that may arise from the non-compliance with such representations and guarantees.

Below is the basic information on the processing of personal data derived from the communications made to the Ethics Committee via the Ethics Channel:
Responsible party
INDUSTRIAS TITÁN, S.A.U.
Purpose
Recording, management, analysis, investigation, resolution and response to the communications made to the Ethics Committee through the Ethics Channel of TITÁN, in accordance with the provisions of the Code of Ethics and of the Protocol for management, investigation and response to communications received by the Ethics Channel of TITÁN.
Legitimation
Compliance with TITAN’s legal obligations.
Creation and maintenance of internal complaints systems.
Satisfying TITAN’s legitimate interests.
Recipients
The following may have access to the personal data:

(i) companies of the TITAN Group;

(ii) those third parties to whom TITAN is legally or contractually obliged to provide them to; and

(iii) companies to which TITAN entrusts advisory, consulting and internal management services.
Rights
Access, modification, deletion and portability of the personal data; limitation or opposition to their processing; and submitting a claim before the Spanish Data Protection Agency.
Additional information
TITAN Privacy Policy available at https://www.titanlux.es/en/legal/privacidad.