Whistleblower system


Information System

Through the channel https://Medinsa.integrityline.com, employees and third parties professionally or commercially related to Laboratorios Medicamentos Internacionales, S.A. ("Medinsa") can quickly and easily report unlawful, unethical or unregulated conduct, as well as make queries regarding regulatory compliance that may arise during their relationship with the companies.

This channel should not be used to falsely or deliberately accuse others and should not be used to provide misinformation.
Communications may be made anonymously or by providing identifying information. In both cases, subsequent communications with Medinsa may continue anonymously if the informant so wishes. All communications shall be treated in a strictly confidential manner, respecting, where applicable, the anonymity of the informant and the data protection regulations in force. The information provided will only be accessible to the compliance officer and persons authorised by the companies.

The documentation provided together with the communication shall be subject to a prior and automatic metadata elimination process, thus eliminating any information that could identify the informant. Similarly, in the case of a verbal communication, the system will previously distort the voice to prevent its identification. More information on confidentiality and anonymity guarantees can be found in the "Anonymity" section.

In any case, whether the informant has accessed in a nominative or anonymous manner, he/she may maintain communication with Medinsa through the "Secure Communication Mailbox" enabled in this System whenever he/she deems it necessary or in order to monitor his/her communication. Through this Mailbox you may access your file by entering the case number assigned to it and the password you have created.

The personal data provided in your communication will be processed, depending on the facts communicated, by Medinsa for the purpose of analysing and investigating the facts sent through the channel, legitimised in compliance with a legal obligation. You can find more information on the processing of your data in the "Privacy Policy" of the channel itself, and contact or exercise your data protection rights through protecciondedatos@medinsa.com.


Anonymity

This channel guarantees the confidentiality and anonymity of the communications sent, offering informants the possibility of communicating anonymously. However, if the informant so wishes, he/she may voluntarily identify him/herself.

Anonymous communications shall be afforded the same guarantees of protection and confidentiality as those where the identity of the informant has been provided.

Anonymity shall be guaranteed at all stages of the investigation. Under no circumstances shall the informant's data and identity be disclosed to third parties other than the Compliance Officer or authorised persons of the company.

In the case of a verbal communication, the voice will be previously distorted to prevent its identification by third parties. 

Likewise, the documents attached to the communications will be subject to a prior and automatic process of metadata elimination, removing any information contained in the files that could identify, directly or indirectly, the informant (e.g. IP address, author information, location, etc.). Your privacy and anonymity is thereby guaranteed.

However, in order to ensure that the information is sent anonymously, we recommend the informant to take the following into account:

  • Do not write your personal information in the communication.
  • If it is not necessary for the investigation, avoid providing personal data of third parties.
  • Make sure that the enclosed information does not include written personal data.
  • If possible, do not send particularly sensitive information (e.g. health data, medical reports, etc.).
  • If possible, avoid reporting from a company device.
  • Maintain confidentiality about the communication submitted and the status of the investigation.