{"id":2070,"date":"2024-07-08T13:58:06","date_gmt":"2024-07-08T11:58:06","guid":{"rendered":"https:\/\/www.miller-ingram.com\/?page_id=2070"},"modified":"2024-10-02T11:29:32","modified_gmt":"2024-10-02T09:29:32","slug":"sistema-interno-de-informacion-canal-etico","status":"publish","type":"page","link":"https:\/\/www.miller-ingram.com\/en\/sistema-interno-de-informacion-canal-etico\/","title":{"rendered":"Confidential channel for Ethical and Criminal notifications"},"content":{"rendered":"
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Confidential channel for Ethical and Criminal notifications<\/h4>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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Approval of the Internal Information System and Protection of Informants and Affected Persons (Ethical Channel)<\/h5>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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In accordance with MILLER-INGRAM's commitment to a true culture of ethics and compliance<\/strong>, as well as to the effective execution of the Code of Ethics and Conduct, the Criminal Compliance Policy,<\/strong> the Protocol for the prevention, detection and action against harassment, sexual assault, and\/or discriminatory acts, and other related internal regulations, and in accordance with the provisions of art. 31 bis 5.4 of the Spanish<\/strong> Penal Code and Law 2\/2023<\/strong>, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption, the Organization has implemented an Internal Information and Protection System for the Informant and Affected Persons<\/strong> - Ethical Channel (hereinafter also \"Internal Information System\", \"Ethical Channel\" or \"the System\").<\/p>

All of this within the framework of our Compliance System<\/strong>, and the protection of our image and reputation, responding to our commitment to regulatory compliance and the strengthening of the culture of participation and internal communication as a mechanism to prevent and detect irregular conduct, as well as to guarantee the protection of whistleblowers against possible reprisals.<\/p>

Consequently, the management body of MILLER-INGRAM ASSOCIATES SL and its parent company <\/strong>have approved the creation and implementation of the Internal Information and Informant Protection System<\/strong> unique to the Group, in accordance with the provisions of the aforementioned Law 2\/2023<\/strong>, and in accordance with the principles and requirements established in the aforementioned regulation.<\/p>

Within this framework, the Organization has enabled internal channels for communicating infractions<\/strong> (\"Internal System for Information and Protection of Informants and Affected Persons\") as a procedure for nominal and confidential or anonymous communication in order to report or bring to its attention<\/strong>, in good faith and based on reasonable indications, possible risks, non-compliance or irregularities<\/strong> included in the scope of the indicated Internal System, as well as to transfer queries or any suggestions for improving <\/strong>the system of compliance and respect for the law, and other regulations of the Organization.<\/p>

And this as an appropriate and effective way to facilitate the detection, discovery and sanction<\/strong>, through the collaboration of all, of possible irregularities or non-compliance<\/strong>.<\/p>

It also aims to provide adequate protection against retaliation that may be suffered<\/strong> by individuals who report <\/strong>any of the actions or omissions that may constitute violations referred to in the aforementioned Law 2\/2023.<\/p>

MILLER-INGRAM has chosen to establish a specialised external management system (reception of communications), with the aim of providing it with greater professionalism and autonomy, and offering appropriate guarantees of respect for independence, confidentiality, data protection and the secrecy of communications.<\/p>\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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Purpose of the Internal Information System and Protection of the Whistleblower<\/h5>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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It is a System that facilitates the preferential channel for bringing to the attention of MILLER-INGRAM information about actions or omissions that may constitute infractions, <\/strong>which has been obtained (i) in an employment or professional context (ii) within the framework of an employment or statutory relationship that has already ended (iii) volunteers (iv) interns (v) workers in training periods regardless of whether or not they receive remuneration (vi) as well as by those people whose employment relationship has not yet begun in cases where the information about infractions has been obtained during the selection process or pre-contractual negotiation.<\/p>\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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Regulation of the Internal Information System and Defense of the Whistleblower<\/h5>\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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The complete regulation<\/strong> of the Internal Information System and Protection of the Informant is found in the General Policy of the Internal Information System<\/strong> and Defense of the Informant and the Procedure for Management of Received Information and Internal Investigations<\/strong>.<\/p>

You can access the full text<\/strong> of the document at the link provided below<\/strong>. Below we also highlight a summary<\/strong> of some of its contents as a guide to facilitate the use of the information channels<\/strong> established to report violations or make inquiries.<\/p>

The general principles and requirements of the System <\/strong>(developed in detail in the indicated document containing the aforementioned General Policy and Management Procedure) are: Regulatory compliance, accessibility, good faith, protection of the whistleblower and the principle of non-retaliation, confidentiality and anonymity, secrecy, objectivity and impartiality, transparency, adherence to the guiding principles of the legal system, traceability and security, data protection, possibility of prior knowledge by the Organization itself, integration into the System of the Organization's various internal information channels, person responsible for the System and due diligence, implementation by agreement or decision of the Administrative Body, independent and differentiated from other entities, and absence of retaliation.<\/p>\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t

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