What is a whistleblower channel?
In view of the commitment of Palma Pictures TMPC to comply with applicable external regulations and its own internal policies and code of conduct or ethics, Palma Pictures TMPC urges employees to report any breach of these regulations, if they know or have reason to believe that any member of the organisation is acting in violation of the law, its code of ethics or any of its policies.
Since we at Palma Pictures TMPC are committed to acting transparently and upholding ethical standards, we provide employees with a critical line of communication, in the form of the Whistleblower Channel, which guarantees the confidentiality of information and the whistleblower's identity. Moreover, we would like to express our gratitude to all our employees who have used the channel since their actions serve to enhance the company's integrity and sustainability.
1. Right to prior information
After a report is filed, easy-to-understand information about the entire process must be made available to the whistleblower. As such, we at Palma Pictures TMPC undertake to duly inform the whistleblower of all the steps involved in the reporting procedure.
2. Right to use the information in an exclusive capacity.
The information reported by the whistleblower may only be used in connection with the investigation.
3. Right to confidentiality
Palma Pictures TMPC All information received and processed via this whistleblower channel will be treated in confidence. Whistleblowers should note that they will only be required to disclose data that are absolutely necessary for the purpose of processing the report, when they complete the reporting form and during the investigation. Moreover, these data will only be accessible to authorised personnel.
4. Right to receive "acknowledgement of receipt" Palma Pictures TMPC will inform whistleblowers that their report has been received within a maximum period of 7 days.
5. Right to receive reasonable information
Palma Pictures TMPC whistleblowers will be informed of the status of the report within a maximum period of three months of the acknowledgement of receipt.
6. Right to a transparent investigation undertaken by an impartial actor
Reports or queries will be processed with absolute transparency and impartiality by those responsible for conducting the investigation. These investigators will be sufficiently and appropriately briefed so that they are able to respond to the questions of whistleblowers or to process the corresponding report.
7. Data protection rights
Palma Pictures TMPC All the data disclosed by whistleblowers via the whistleblower channel will be processed in accordance with applicable data protection regulations.
8. Right not to face retaliation
Palma Pictures TMPC As no form of retaliatory action may be taken against whistleblowers, they will not be held responsible for the information contained in the report, unless it has been filed in bad faith.
Obligations and warnings
Palma Pictures TMPC Any whistleblowers who use the following channel are reminded that their report must be filed in good faith.
Whistleblowers are deemed to have filed a report in bad faith if they are aware that the allegations are false; they show a blatant disregard for the truth; or their intention is to exact revenge, harm Palma Pictures TMPC or harass or discredit the suspect, or undermine their employment, professional or personal prospects.
If there is evidence to suggest that a report has been filed in bad faith, whistleblowers will not be protected and may face both disciplinary and criminal action.
Obtaining evidence to substantiate a report in accordance with the law. It should be noted that any evidence submitted in support of a report must be obtained in accordance with the law. Otherwise, Palma Pictures TMPC may inform the corresponding judicial authority if it deems that evidence has been obtained unlawfully.
Reasons for rejecting reports
Palma Pictures TMPC The report may be rejected in the following cases:
1. The allegation is not credible; the claim is unsupported; or the report is filed as a result of a dispute.
2. Claims that are obviously baseless, unsubstantiated or described in general or imprecise terms, unless steps are taken to address this situation.
3. Any type of conduct not referred to in this document Palma Pictures TMPC
4. If the information is simply reproduced from a previously rejected or duly investigated case.
Who can file a report?
Any employees of the company, members of the board of directors and senior management, and former employees or anyone involved in the recruitment process, in accordance with applicable regulations.
If I file a report, can I be sure that I will not face retaliation? Is the suspect informed that the report has been filed?
In accordance with applicable regulations and the rules governing this whistleblower channel and the investigation procedure, the company guarantees that whistleblowers who file a report in good faith will not face retaliation.
Moreover, whistleblowers will be protected if there is reason to believe that the reported allegations are true.
Palma Pictures TMPC may also introduce any necessary support measures (advice, assistance from authorities and the organisation in cases of retaliation, or even legal assistance).
On the other hand, the suspect will not be informed of the procedure until the investigation has been concluded.
What is the procedure for processing the report? How long will it take to complete the procedure?
Once the report has been filed via the corresponding form, the whistleblower will be sent an email acknowledging receipt of the report within a maximum period of seven days.
The whistleblower will then be informed of the outcome of the internal investigation within a maximum period of three months, unless the report relates to a criminal offence, in which case it may take up to 6 months to complete the procedure from receipt of the report.
Can I file a report without proof?
Yes, although it is better to submit proof or evidence of the reported allegation, otherwise the investigation may be impeded or the report dismissed. The reporting form gives whistleblowers the opportunity to upload additional documentation, although they are under no obligation to do so.
What happens if my accusation is false?
Provided that you file a report in good faith, if your suspicions prove to be misguided or unsupported, they will simply be dismissed once you have been informed.
Otherwise, if your report is false and has been submitted in bad faith, you may be charged with slander or defamation under our Criminal Code (Articles 205 et seq.); moreover, you will not be protected and may face both disciplinary and criminal action.
To what extent are the data disclosed in the report protected?
In addition to the aforementioned guarantee of confidentiality, all the personal data disclosed in the report will be processed in accordance with the internal data protection policy and measures of. Palma Pictures TMPC.